property and began commercial nuclear fuel production. Westinghouse purchased the
facility in April 2000. There are currently no manufacturing operations at the site.”
“Primary functions at the site throughout its history have included the manufacture of
uranium metal and uranium compounds from natural to enriched uranium for its use as
nuclear fuel. Specifically, operations included the conversion of uranium hexafluoride gas
of various uranium 235 enrichments to uranium oxide, uranium carbide, uranium dioxide
pellets, and uranium metal. These products were manufactured for use by the federal
Government, government contractors, and for use in commercial and research reactors,
approved by the Atomic Energy Commission. Research and development was also

conducted at the site, as were uranium scrap processes.” { EXHIBIT A21-22}

At times during the plants history the powder was made into pellets, which where then
stacked into hollow metal tubes, that is the uranium fuel rods for reactors. Some of the
fuel rods were shipped to commercial nuclear power plant reactors.

The uranium hexafluoride gas processed at the Hematite site was trucked in from the U.S.
governments uranium enrichment plant in Paducah, Kentucky. Some may have came
from Oak Ridge, Tennessee and/or Piketon, Ohio enrichment plants,

Much of the uranium that was processed at Hematite was from the “front end” of the
uranium fuel cycle. That is, it was naturally radioactive uranium that had been mined,
milled, chemically converted, and enriched, but had not been fissioned in a reactor. (To

quote from Daniel F. Ford’s book, Three Mile Island -Thirty Minutes to Meltdown, 1982:

“in a controlled nuclear reaction {In a reactor vessel], uranium nuclei fission--split apart--

with a consequent release of thermal energy...” [page 24].

3


, @ @

Covered Employee NIOSH ID# GoTo

Introduction

The Energy Employees Occupational IHness Compensation Program Act of 2000
(EEOICPA), Executive Order No. 13179, and the Radiation Dose Reconstruction Rule
(42 CFR 82)!

EEOICPA established a compensation program to provide a lump sum payment of $150,000 and
medical benefits as compensation to covered employees suffering from designated illnesses
incurred as a result of their exposure to ionizing radiation, beryllium, or silica while in the
performance of duty for the Department of Energy and certain of its vendors, contractors, and
subcontractors. This legislation also provided for payment of compensation to certain survivors
of these covered employees.

In Presidential Executive Order No. 13179, the President designated the U.S, Department of
Labor to administer this program for claims by current and former employees of nuclear
weapons production facilities and their survivors who seek compensation for cancers caused by
radiation exposures sustained in the performance of duty. The Executive Order also directed the
Department of Health and Human Services to estimate (reconstruct) the radiation doses received
by these employees. The Department of Labor uses the reconstructed radiation dose in
evaluating whether the employee's cancer was at least as likely as not related to employment at
the facilities covered by EEOICPA. To fulfill the responsibilities assigned to the Department of
Health and Human Services, the National Institute for Occupational Safety and Health’s
(NIOSH) Office of Compensation Analysis and Support (OCAS) completes dose reconstructions
using the methods described in the Radiation Dose Reconstruction Rule (42 CFR 82)! for the
Department of Labor's use in making compensation decisions.

The Purpose of Radiation Dose Reconstruction

A radiation dose reconstruction is used to estimate the radiation dose received by the specific
organ(s) in which a worker developed cancer, particularly when radiation monitoring data are
unavailable, incomplete, or of poor quality. Even in instances when radiation dosimetry data are
available, they rarely specify dose to an organ and often are based on monitoring procedures that
do not meet modern standards.

The basic principle of dose reconstruction is to characterize the occupational radiation
environment to which a worker was exposed using available worker and/or workplace
monitoring information. In cases where radiation exposures in the workplace environment
cannot be fully characterized based on available data, default values based on reasonable
scientific assumptions ate used as substitutes.

EEOICPA recognized that the process of estimating radiation doses would require dealing with
uncertainties and limited data and thus required that the government establish methods for
arriving at reasonable estimates of radiation dose received by an individual who was not
monitored or inadequately monitored for exposures to radiation, or for whom exposure records
are missing or incomplete. To the extent that the science and data involve uncertainties, these
uncertainties are typically handled to the advantage, rather than to the detriment, of the claimant.
NIOSH has used the best available science to develop the methods and guidelines for dose

DRAFT Page 2 of 8

A-tl


Report
Death of
An employee of Hematite Nuclear Plant

am writing this report in reference to the death of my husband,
_ died as a result of exposure to a toxic substance he
inhaled while on duty as a security guard at the Hematite Nuclear piant.
worked there twenty one years and two weeks before his retirement.

The incident which caused the exposure occurred as he was makina his rounds
of the plant and discovered a leaking anhydrous ammonia tank was told to
find the shutoff valve and to turn it off. In his attempt to find the valve, he was
overcome by toxic fumes.

_ doctors have stated that his lungs were irreversibly scarred by these
toxins and that he died from this exposure about fase years after the incident. He
was on oxygen the last two years of his life. Severn;

Workers were not informed of the dangerous materials to which they were
exposed. They were not furnished masks or other protective devices when
working in those high risk areas.

retired on 1988 and died 2002. An autopsy was
performed and it confirmed that death was due to inhalation of a toxic substance
causing scarring of lung tissues.

| have his x-rays and medical records which show the deterioration of his lungs
from the exposure to the toxins and his death.

It is my belief that more could have been done to keep my husbarx

as well as other employees of the Hematite Nuclear Plant safe, that the company
was negligent in this regard and that my husband died because of this
negligence.

Sinroraly Youre

June 11, 2008 \ | Wy v| 12[08

lotary Publi¢»Netary
State of Missouri

J defferson County

§ My Commission Expires Jan. 7, 2010

eer Sol asion # 06552589



« AOC #15 Joachim Creek Bridge. This area was included as an AOC to investigate if materials were
buried at this location. No sampling was planned for this AOC (LBG 2003). A geophysical survey
was conducted to investigate the AOC (Geophex 2005, also summarized in Sect. 2.8).

The AOCs generally align with the Hematite Site features that are described in Sect. 1.4 of this RI
report. With the exception of Joachim Creek Bridge, which was addressed through a geophysical survey

(Geophex 2005), the RI field activities were conducted such that soil, sediment and/or groundwater
samples were collected from each of the AOCs.

1-14

Re



9.

References

42 CFR 82, Methods for Radiation Dose Reconstruction Under the Energy Employees
Occupational Illness Compensation Program Act of 2000; Final Rule, Federal
Register/Vol.67, No. 85/Thursday, May 2, 2002, p 22314.

42 CFR 81, Guidelines for Determining the Probability of Causation Under the Energy
Employees Occupational Iliness Compensation Program Act of 2000; Final Rule,
Federal Register/Vol.67, No. 85/Thursday, May 2, 2002, p 22296.

NIOSH, (2007) External Dose Reconstruction Implementation Guideline, Rev 3, OCAS-
1G-001, National Institute for Occupational Safety and Health, Office of Compensation
Analysis and Support, Cincinnati, Ohio.

NIOSH, (2002) Internal Dose Reconstruction Implementation Guideline, Rev 0, OCAS-
1G-002, National Institute for Occupational Safety and Health, Office of Compensation
Analysis and Support, Cincinnati, Ohio.

NIOSH, (2007) Radiation Exposures Covered for Dose Reconstructions under Part B of
the Energy Employees Occupational Illness Compensation Program Act, Rev 0, OCAS-
1G-003, National institute for Occupational Safety and Health, Office of Compensation
Analysis and Support, Cincinnati, Ohio.

ORAUT (Oak Ridge Associated Universities Team), /nternal Dosimetry Organ, External
Dosimetry Organ, and IREP Model Selection by ICD-9 Code, Revision 02 PC-1,
ORAUT-OTIB-0005, February 10, 2006,

Battelle-fBD-6001, Site Profiles for Atomic Weapons Employers that Refined Uranium
and Thorium, Appendix D, United Nuclear Corp., March 14, 2008.

ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0006, Technical
Information Bulletin: Dose Reconstruction from Occupationally Related Diagnostic X-
Ray Procedures, Rev 02, December 21, 2005.

ACJ Associates, Inc., (2004), User Manual for IMBA Expert, OCAS-Edition, ACJ
Associates, Richland, Washington.

SENES Oak Ridge, Inc. (2007), User's Guide for the Interactive RadioEpidemiological
Program (NIOSH-IREP), June 2007.

DRAFT Page 7 of 8

Alb


Special Exposure Cohort ai U.S. Departmen Pica and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
IIness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Appendix — Petitioner 3

Survivor Information — Complete Section B if you are a Survivor or representing a Survivor.

Mr/Mrs./Ms. First Name Widate iniual Last Name -

B.2 Social Security Number of Survivor:

B.3. Address of Survivor:

Gran Ant # P.O. Box

City” State Zip Code
B.4. Telephone Number of Survivor:
B.5 Email Address of Survivor:

B.6 Relationship to Employee: youse ion/Daughter ?arent
randparent 3randchild

Employee Information — Complete Section C.

C.1. Name of Emnlavaa: -_

Mc/Mrs.nis. cust ware WHUUIE Huet Last wane

C.2 Former Name of Employee (e.g., maiden name/legal name change/other):

Mr/Mrs./Ms. First Name Middle Initial Last Name
C.3. Social Security Number of Employee:

C.4__ Address of Employee (if living):

Street
City State Zip Code ~
C.5 Telephone Number of Employee: ( ). :

C.6 Email Address of Employee:

C.7 Employment Information Related to Petition:
C.7a Employee Number (if known):

C.7b Dates of Employment: Start End

C.7¢ Employer Name: Molhaclradt to Bul€ +n UNC to ABB + Weskns
C.7d Work Site Location: emake Site Rema kite Mo y

C.7e Supervisor's Name:

a

Name or Social Security Number of First Petitioner:



PAH polycyclic aromatic hydrocarbon
PCB polychlorinated biphenyl

PCE perchloroethylene

pCi/g picoCuries per gram

pcv/L picoCuries per liter

PGDP Paducah Gaseous Diffusion Plant
PID photoionization detector

ppb parts per billion

ppm parts per million

PRG preliminary remediation goal
238py plutonium-238

PVC polyvinyl chloride

QAPP Quality Assurance Project Plan
Qc quality control

Ra radium-226

RI remedial investigation

RCOPC radiological contaminant of potential concern
SAIC Science Applications International Corporation Kes eayclr
S.u, standard unit

SVOC semivolatile organic compound
"Te technetium-99

TCE trichloroethylene

Th thorium-232

TSWP task-specific work plan

UFs uranium hexafluoride

UNC United Nuclear Corporation
USCS Unified Soil Classification System
USGS U.S. Geological Survey

UTL upper threshold limit

voc volatile organic compound

WEC Westinghouse Electric Company, LLC

ALG © Nasoours Copan. Life Cibria

Lr: mavbtie < Mbdc but- >tHan ee
Mbe. sang vapecipic

backarowrd nal 2b.
ea pos

Deunl ‘s Masntain

xvi

4a.


@ e
Kcem Kepplen.- MOV 4 78

licensee then sent samples to a consultant laboratory for analysis. The
results indicated that the elevated gross beta activity was due to Tc-99
(half life of 2.1 x 105 years),

The licensee pursued this matter with NRC's Office of Nuclear Material
Safety and Safeguards to clarify authorization to Possess and process this
waste. NRC granted permission to dispose of this waste. The waste was
filtered through an ion exchange colum and disposed of via the site
evaporation ponds. All discharges were within the limits of 10 CFR 20,
Appendix B, Table II. No credit was taken for adsorption on the soil
beneath the ponds or for dilution in the ground water.

Question 4.d

d, Woukd you please tell me what Levels 0f beta and alpha the NRC
Anspectors have found when they have tested the Liquid nadwaste
discharge prior, to its release into the ponds? When were these
tests Last performed?

Answer

We did not collect a sample of radwaste discharge to the evaporation ponds.
Samples were collected from the laundry waste tank and the site pond for
comparison with the licensee's results. These comparisons are presented in
Table II of the attached inspection report.

Samples were taken from these sources because they represent the majority
of radwaste liquid discharge directly to the environment. Comparative
samples of radwaste discharges to the evaporation ponds will be collected
during a future inspection.

Question 4.2

@. 18 fresh water used to ditute the Liquid radwaste prion to its
being measured for discharge to the ponds? I§ 40, what is the
natio of sresh-to-contaminated water?

Answer

Effluents from the wet scrubber system and UFg cylinder heel washing
and processing operations in Building 240 are discharged to evaporation
ponds located within the fenced plant area. Prior to discharge, this
waste water is analyzed to ensure that uranium concentrations are
within 10 CFR 20, Appendix B, Table II limits. There is no fresh water
added for dilution purposes to the discharges to the evaporation ponds.


@ UNITED STATES
LEAR REGULATORY COMMISSION
REGION I
799 ROOSEVELT ROAD
GLEN ELLVN, ILLINOIS 60137

Te pp. 6-7

November 24, 1978

Mrs. Leo Drey
515 West Point Avenue
University City, MO 63130

Dear Mrs. Drey:

This is in response to your letters dated October 13 and 18, 1978,
requesting additional information about our inspection program for the
Combustion Engineering uranium fuel fabrication plant at Hematite,
Missouri.

Enclosed with this*letter is a copy of our most recent confirmatory
measurements inspection of September 20 and October 17, 1978. Included
in that report are results of environmental and effluent samples which
were collected in May of 1978. Additionally, we are enclosing a copy
of the final Environmental Impact Appraisal as xvequested in your letter.

The NRC has accepted the invitation of the Missouri Clean Water
Commission to participate in a public hearing regarding public concerns
over Combustion Engineering's radioactive effluent discharges. The
meeting is tentatively scheduled for 1:00 p.m. on November 30, 1978,

in Hillsbero, Missouri. -

We hope the enclosed information will be helpful in resolving your
concerns about this facility.

Sincerely, °

Tet G. conn

Director

Enclosures:

1. - Responses to questions

2. Final Environmental Impact Appraisal
3. IE Inspection Rpt No. 70-36/78-07

cc w/encl 1:

W., Lamar Miller, Ph.D., USEPA Region VII
Richard F, Rankin, MCWC

3. G. Davis, Acting Director, IE

J. H. Sniezek, IE

J. B. Martin, NMSS

ft -a3


@ '@ "oy aeinestas

Anvestigation ta Determine the Source of "Tc
in Groundwater Monitoring Wells 17 and 17B

5.0 CONCLUSIONS

In 1982, increased beta activity was detected in groundwater monitoring well RMC 9 by an NRC
contractor. In 1996 it was determined that the increased beta activity in WS17 which had
replaced RMC-9 was due to ® Tc. It was speculated that surface water accumulations of ® Te
around the vicinity of WS17 during high rainfall events may have introduced ” Te into the well
since the construction details of that particular monitoring well is not known. In June, 1996,
WS17 was properly abandoned and replaced with a properly installed monitoring well designated
as WS17B. WS17B contained concentrations of ® Tc; indicating the occurrence of ® Tc in
WS17 was not confined to WS17..

In August, 1996, Gateway performed a field investigation to assist CE in determining the source
ofthe * Tc detected in monitoring well WS17/WS17B. This investigation revealed the

following: .

¢ Anexamination of the groundwater contour map (Figure 4-1) and the groundwater iso-
concentration map (Figure 4-3) indicates that ® Tc (indicated by gross beta activity)
entered the groundwater system within the vicinity of the former ring storage area and
traveled down-gradient toward monitoring wells WS17 (abandoned) and WS17B
(replacement well). The groundwater mound observed beneath the former ring storage
area transmitted a small quantity of the contamination in the direction of plant north (as
observed in GWE 2, GWE 8 and WS13). However, the majority of the contaminant
migration has been directed to the plant south.

¢ The center of the plume indicated by highest concentrations of gross beta activity in
groundwater is located beneath the former ring storage area.

¢ The highest concentrations of * Tc (of the wells that were analyzed for Tc) in
groundwater is located slightly plant south of the former ring storage area.

¢ The soils beneath the former ring storage area, with the exception of surface soil samples
at GWE-1, GWE-10, and GWE-5, appear to display no residual effects of the
contamination above CE’s established background concentration (assuming that the
contamination was introduced from the surface and that highly soluble forms of * Tc

would still be present.)

+ The average surface soil gross beta concentration of 41 pCi/gm in the area of former
WS17 and WS17B does not appear to be the cause of the groundwater contamination in
that area. The gross beta iso-concentration map (Figure 4-3) indicates that the area
beneath WS17/WS17B is located down-gradient of the center of the contamination
plume which originates at the former ring storage area. Additionally, a concentration of
41 pCi/gm is only slightly greater than CE’s background concentration. Gross Beta
concentrations in soil at this level are unlikely sources of groundwater contamination.

I-24 3


Cy

the MEN |
¥ from MECHANICAL



E ICA for Response Action for off-site Groundwater ;

January 2003

These products were manufactured for usé by the federal government) a

ad government

contractors and by commercial and research reactors approved by the ‘Atomic Energy
Commission. Research and development was also conducted at the Site,/as were uranium

scrap recovery processes.
|

2.1.2 Off-Site Groundwater Impacts

In December 2001, the Missouri Department of Health and Senior Se
conducted annual radiological monitoring (gross alpha/gross beta) of four pri

vices (DHSS)
ate wells near

the Site. Samples were also collected for;volatile organic analyses at the/ request of the
Department of Natural Resources. Results of that sampling revealed that one. of the private
drinking water wells sampled by DHSS exhibited VOC concentratipns, including

tetrachloroethylene (PCE), and trichloroethylene (TCE), above drinking)

jater standards.

This well (i.c., Well #3) is located northeast of the FFCF at a residende situatéd on
Westinghouse property and leased by Westinghouse. This weil had been last sampled in 1996

for VOCs, and did not contain VOCs at that time. Once informed o
Westinghouse and the Missouri Department, of Natural Resources (DNR). ¢01
up testing. In March 2002, Westinghouse tested an additional 20 wells, five
found to be impacted by VOCs, (bringing the total number of affected wells t
2002, DNR and DHSS sampled additional private wells, while Westinghi
repeat sampling of those previously sampled. Analytical results of this sa
April showed no additional private wells were affected. In July 2002, ith
quarterly sampling was conducted; and detectable levels of VOCs were foui
wells, bringing the total number of affected wells to eight. Except for the iw
affected wells are at residences located in.the affected area located southe;
Figure 2 shows the affected area. ;

f this finding,
ducted follow-
of which were
o six), In April
use conducted
pling event in
first round of
id in two: more
1] #3, all.of the
fast of the Site.

: |
The affected wells are all reportedly open to both the Jefferson City Formation and the

underlying Roubidoux Formation. Hydrogeologic evaluations of the S te|

area (Leggette,

Brashears & Graham, Inc., November 2002) have concluded that. gioundwater ‘in the
Jefferson City Formation has been impacted by the VOCs of interest, whergas groundwater in

the deeper Roubidoux Formation generally has not, 1

Based on these findings, and in consultation'with DNR, Westinghouse detel m!

ined that a time-

critical removal action was appropriate to mitigate potential risks to residents in the vicinity of

the Site. Westinghouse prepared an Action Memorandum (Action Memorandum, Former

Fuel Cycle Facility, Off-site Groundwater, June 2002) to document its respons
of the Action Memorandum are discussed in Section 2.2. i

i
i
2.2. Previous Removal Actions |
Previous investigations are described in detail in the Action Memorah
Actions taken subsequent to those investigations are presented below.

“| |
Major components of the Action Memorandum that Westinghouse has implemented inchide

the following: |

|

e, Components

dim, Sine: 2002.

CABRERA SERVICES, INC.

PAGE 4}

002370



States that “Residual radioactivity was assumed to remain at the site until 2006.”

The fact that the presence of technetium-99 was not identified announced to the public
{EXHIBIT A23-30 Kappler letter Nov 24, 1978}, or detected in the evaporation
ponds until 1976.

Some 50 years later it is clear and concise evidence that all workers from
1958-present should be included in this special exposure cohort due to residual
contamination from nuclear weapons activities, given the half life of Technetium alone
Is 211,000.000 billion years, and NIOSH Omission of residual radioactivity until 2006

{EXHIBIT A-13}

Although the Hematite Site is designated as an AWE facility and not a BE, beryllium was
very much present at the Hematite Site as noted in a report presenting the results of the
(RD Remedial Investigation Report prepared for Westinghouse Electric Company (WEC)
by Science Applications International Corporation (SAIC) under contract to (WEC) Page
1-4 states as follows:

“During the period prior to the purchase of the property in 1971 by Gulf United Nuclear
Fuels Corporation, classified government projects dominated Hematite facility
operations. As such, specific details regarding the exact nature of production processes
prior to 1974 are not known. The following are examples of known projects during this
time (section 2.2,page 4 of (LBG 2003);
¢ Production of uranium metal for use in the US navy’s nuclear-powered submarines

and destroyers;
© Production of specialized uranium oxides for use in the US army’s army package

power reactor;
© Production of highly enriched uranium oxides for a general atomics gas-cooler


reconstruction. These methods have been reviewed and commented upon by the public,
including experts in the field of dose reconstruction, and the Presidentially-appointed Advisory
Board on Radiation and Worker Health.

How Radiation Doses Are Reconstructed

NIOSH reconstructs radiation doses by evaluating all available, appropriate data relevant to the
employee's radiation exposure. Some examples of data that may be included in the dose
reconstruction include, but are not limited to, internal dosimetry (such as results from urinalysis),
external dosimetry data (such as film badge readings), workplace monitoring data (such as air
sample results), workplace characterization data (such as type and amount of radioactive material
processed), and descriptions of the type of work performed at the work location.

Although the specific methods used for each dose reconstruction may vary, after a claim has
been referred by the Department of Labor to NIOSH for a dose reconstruction, NIOSH typically
requests the worker’s personal radiation monitoring information from the Department of Energy.
Upon receipt of the requested information, at least one voluntary informational interview with
the claimant and/or survivors is conducted and a copy of the interview report is sent for review.
After all of the necessary and available information is gathered, a dose is estimated, using the
methods in the Radiation Dose Reconstruction Rule. After a NIOSH health physicist reviews the
information, methods, and results, the claimant receives a draft copy of the dose reconstruction
report followed by a concluding interview, during which the claimant can add any additional
relevant information that may affect the dose reconstruction. If the claimant certifies that he/she
has completed providing information and that the record for dose reconstruction should be
closed. a final dose reconstruction report is sent to the claimant, the Department of Labor, and
the Department of Energy.

As applied in the EEOICPA, dose reconstructions must rely on information that can be
developed on a timely basis and on carefully stated assumptions. Therefore, the guiding
principle in conducting these dose reconstructions is to ensure that the assumptions used are fair,
consistent, and well-grounded in the best available science, while ensuring that uncertainties in
the science and data are handled to the advantage, rather than to the detriment, of the claim when
feasible. When dose information is not available, is very limited, or the dose of record is very
low, NIOSH may use the highest reasonably possible radiation dose, based on reliable science.
documented experience, and relevant data, to complete a claimant’s dose reconstruction, In
other instances, NIOSH may not need to complete fully a dose reconstruction because a partial
dose reconstruction results in an estimated dose which produces a probability of causation of
50% or greater.

How Radiation Dose Reconstructions Are Used in Final Compensation Determinations
The results of an employee’s dose reconstruction are used by the Department of Labor to
determine the probability that a worker’s cancer was “at least as likely as not” due to his/her
occupational exposure to ionizing radiation during employment at a covered facility. Criteria and
guidelines for making this determination are established by EEOICPA and the Probability of
Causation Guidelines (42 CFR 81 )2. The dose reconstruction is not the final determination of a
claim, but rather an interim product that is used by the Department of Labor in making its final

DRAFT Page 3 of 8

A-12.


ACRONYMS

ABB Asea Brown Boveri

AMSL above mean sea level

AOC area of concern

Am americium-241

BGS below ground surface

BNA base-neutral-acid extractable organic
CCOPC chemical contaminant of potential concern
CE Combustion Engineering Inc.

coc chain-of-custody

CSM conceptual site model

DCE dichloroethylene

DNAPL, dense, nonaqueous-phase liquid

DO dissolved oxygen

DOE U.S. Department of Energy

DPT direct-push technology

DSCC deeper silty clay/clay

ECD electron capture detector

EM electromagnetic

EPA USS. Environmental Protection Agency
F&T fate and transport

FID flame ionization detector

FS feasibility study ?
GAC General Atomic Company ——~—-- .
Gulf Gulf Oil Corporation

GM Geiger-Mueller ——~7
gpd gallons per day

gpm gallons per minute

HDPE high-density polyethylene

HSA hollow-stem auger

HSU hydrostratigraphic unit

ID inside diameter +
IDW investigation-derived waste f
KOH potassium hydroxide

LBG Leggette, Brashears & Graham, Inc.

MDC minimum detectable concentration

MDL method detection limit

MDNR Missouri Department of Natural Resources
MIP membrane interface probe

mL/min milliliters per minute

MS matrix spike

MSD matrix spike duplicate

Nal sodium iodide

Np neptunium-237

NPDES National Pollutant Discharge Elimination System
NSSSC near surface silt/silty clay

NTU nephelometric turbidity unit

0.D. outer diameter

ORP oxidation-reduction potential

XV

4


Spécial Exposure Cohort san U.S. Separmenl Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
Illness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B

re a labor organization.

D.1 Labor Organization Information:

Name of Organization

Position of Contact Person
D.2. Name of Petition Representative:

D.3 Address of Petition Representative:

Street Apt # P.O. Box
City State Zip Code
D.4__ Telephone Number of Petition Representative: ( )

D.5 Email Address of Petition Representative:

D.6 Period during which labor organization represented employees covered by this petition
(please attach documentation): Start End

D.7 Identity of other labor organizations that may represent or have represented this class of
employees (if known):

TT

Name or Social Security Number of First Petitioner:



SUMMARY OF GEOLOGIC AND HYDROLOGIC CONDITIONS

The geologic framework of the Hematite Site is dominated by two key bedrock formations, the
Jefferson City-Cotter Dolomite and the Roubidoux Formation (sandy dolostone and sandstone) that
underlie the Hematite Site. These formations dip gently toward the northeast. The regional landscape is
highly dissected by streams yielding topographic relief in excess of 150 ft locally. The Hematite Facility
is built upon terrace/alfuvial flood plain sediments overlying bedrock within the valley carved by Joachim
Creek, which is located approximately 1000 ft south of the Facility. These sediments include 10 to 20 ft
of fine-grain material underlain by 5 to 20 ft of coarset-grain sands and gravels.

{n the unconsolidated terrace/alluvial flood plain sediments (herein referred to as the overburden),
groundwater flow is chiefly confined to the basal, coarse-grain unit and is in a southeastward direction
from the Hematite Facility toward Joachim Creek where it discharges. A groundwater mound is
associated with the northeast corner of the Hematite Facility and has a significant impact on the
potentiometric surface. Groundwater flow in the upper Jefferson City-Cotter Dolomite appears to be
affected by the mounding, and components of flow radiate from the Hematite Facility toward the
northeast (along bedding planes) and toward the southeast (in a transmissive zone) within this bedrock
unit. Betow the Jefferson City-Cotter Dolomite, the current direction of groundwater flow appears to
reflect a northeasterly direction, which is consistent with the regional groundwater flow direction in the
Roubidoux Formation.

In this RI report, several hydrostratigraphic units (HSUs) in bedrock have been defined. In
descending order of depth, these are the Jefferson City-Cotter, Jefferson City-Roubidoux contact zone,
and Roubidoux HSUs, respectively.

Vertical head gradients are downward from the shallow to deep overburden. Between the deep
overburden, and Jefferson City-Cotter HSU, gradients are downward in the vicinity of the
Hematite Facility and generally upward near Joachim Creek. Vertical gradients tend to be upward from
the Jefferson City-Cotter HSU and deeper HSUs.{However, until approximately mid-2004, this gradient
was reversed (i.e., downward) as a result of the significant lowering of heads in the Roubidoux
Formation. A possible reason for lower heads in the deeper HSUs was the pumping of groundwater from
the Roubidoux Formation by water supply wells in the city of Festusd

SUMMARY OF CONTAMINATION AT THE HEMATITE SITE

Most constituents (radionuclides, metals, and organics) at the Hematite Site are closely associated
with the footprint of the Hematite Facility and disposal sites within the Hematite Facility.

Inorganic constituents were elevated in surface soil, soil and groundwater at known waste areas/areas
of concern within the Hematite Site. These include: the Evaporation Ponds, Deul's Mountain, soils under the
buildings, outdoor areas adjacent to buildings, the Burial Pits and the Site Pond. Because the elevated
metals concentrations in the groundwater are localized, this suggests that groundwater migration of
inorganics is limited and not as extensive as that of chlorinated solvents. There was no indication on of
metals contamination in the bedrock groundwater. ” i

Sediment data indicate the presence of some inorganics in the Site Pond, Site Creek and Northeast Site
Creek. However, the inorganics were generally not detected in the surface water samples from the Site,
suggesting that migration of inorganics through surface water is limited or does not occur.

Technetium-99 Cte) and, to a lesser extent, uranium is evident in soils, but contamination is also
associated with known waste disposal areas (the Evaporation Ponds, Deul's Mountain, Site Pond, Burial

xviii

B44


r) @ Rik

Vol 2
Jan 20077

EXECUTIVE SUMMARY

INTRODUCTION

This Report presents the results of the remedial investigation (RI) conducted at a former fuel cycle
facility that is located within 228 acres of property in Hematite, Missouri, and is currently owned by the
Westinghouse Electric Company, LLC (WEC). WEC ceased facility operations in June 2001 and is
proceeding with Site characterization, remediation, and facility decommissioning. This Report was
prepared by Science Applications International Corporation (SAIC) under contract to WEC.

As used throughout this document, the “Hematite Facility” refers to the central portion of the property,
encompassing the historic primary operations area, Site Pond and burial pits area (approximately 18 acres) s,
while the “Hematite Site” refers to the “Hematite Facility,” and other areas which were the focus of this
investigation based on potential impacts by previous Facility operations. The term “Property” refers to the
entire 228 acres of land owned by Westinghouse.

The objective of this RI is to establish an understanding of the geology, hydrology, and the nature
and extent of contamination in surface water, soils, sediment, and groundwater for the Hematite Site.
Characterization data collected during the RI are being used in risk assessment studies that will quantify
the impact of contamination associated with previous operations on human health and the ecological
environment, The results of the baseline risk assessment will be covered under a separate report. Data
obtained during this i investigation will bé used to facilitate development of feasibility studies for selection
of appropriate alternatives for remediation. Coupled with process knowledge for the Hematite Facility and
known potential source areas for contaminants, this evaluation has led to the development of a conceptual
site model (CSM) from which the fate and transport of contaminants in groundwater have been assessed.
Finally, the CSM has become the basis from which a groundwater flow and transport model has been
constructed and calibrated against empirical data.

The Hematite Facility was originally constructed as the Mallinckrodt Chemical Works in 1955. The
Facility became operational in July 1956, producing uranium metals for the nuclear fuel program of the
U.S. Navy. Throughout its history, the manufacture of uranium metal and compounds from natural and
enriched uranium was the primary activity at the Facility. Operations included the conversion of uranium
hexafluoride gas of various *°U enrichments to uranium oxide, uranium carbide, uranium dioxide pellets,
and uranium metal. Although uranium material production was the primary function at the Hematite
Facility, records indicate secondary activities such as uranium scrap recovery and a limited amount of
work with thorium compounds as part of early research into the use of thorium in the fuel cycle. In
addition to the nuclear materials processed at the Hematite Facility, there was a variety of non-nuclear
chemical products stored on-Site and used in many of the processes. Those with the greatest potential for
contaminating surface water, soils, and groundwater at the Hematite Facility because of leaks (from
storage tanks or process pipelines) or waste disposal activities (e. Evaporation Ponds and the Burial
Pits) include strong miner: ids (hydrochloric, hydrofluoric, and and chlorinated organic solvents
[perchloroethy ene (PCE) ttichloroethylene (TCE)]. A number potential “areas of concern® have”
been identified at the Hematite Site and include those locations where these (and other) potential

contaminants were stored, used, and/or disposed.

xvii

he 42,


CONCEPTUAL SITE MODEL AND NUMERICAL MODELING
The CSM that was developed for this RI focuses on the following key conclusions:

* Flow and transport in a southeasterly direction within the overburden is facilitated by a hydraulic
gradient caused by groundwater mounding under the Hematite Facility and discharge to the surface
in Joachim Creek

¢ With increasing depth below the surface, flow/transport directions gradually shift from southeasterly
(overburden), to a blend of southeasterly and a regionally imposed northeasterly component
(Jefferson City-Cotter HSU), and finally to a regional northeasterly direction (Jefferson City-
Roubidoux contact zone and Roubidoux HSUs)

¢ Contaminant transport in all geologic units projects back to the footprint of the Hematite Facility
{and associated disposal areas) as the ultimate source area

Flow and contaminant migration in bedrock at the Hematite Site may have been potentially impacted
by pumping in deep production wells operated by the city of Festus. These wells were operational until
the summer of 2003 and caused regionally extensive drawdown in the Roubidoux Formation of up to
50 ft in the vicinity of the Hematite Site. In August 2003, the Jefferson County Water Authority brought
online a new production facility that draws water from the sediments marginal to and underlying the
Mississippi River using horizontal wells and now provides nearly all of the water needs for the city of
Festus and other surrounding communities. Startup of this well permitted Festus to place its four
production wells located on the west side of the city on standby. These wells had been pumping
approximately 1 million gpd from the lower Roubidoux Formation. Currently, they are used only during
periods of peak demand in mid- to late summer, or when the collector well is off-line. When
supplementing production from the collector well, the pumping rate on these wells is much less than
before August 2003.

in the residential community southeast of the Hematite Facility, a number of private wells were
completed open hole, which provided a hydraulic connection between the Jefferson City Dolomite and
Roubidoux Formation. Full-capacity pumping of the Festus production wells before the new water facility
was brought on line in August 2003 probably impacted contaminant distribution at the Hematite Site in
several ways. First, hydraulic stresses in the Roubidoux Formation were transferred to the upper Jefferson
City-Cotter Dolomite through these wells (e.g., PW-06, PW-16, and PW-19) and facilitated flow and
contaminant migration in the Jefferson City-Cotter HSU from the Hematite Facility to the location of the
wells. Secondly, downward flow of groundwater and contaminants in these wells spread contaminants to
deeper zones at lower heads imposed by pumping of the Festus production wells. A similar mechanism is
responsible for vertical migration of contaminants at PW-03.

Once the Festus wells were placed on stand by, rebound of water levels in the Roubidoux Formation
progressed rapidly and the potential for downward flow through the private wells declined. The changes
in the hydrologic regime since the Festus production wells were no longer pumping at full capacity will
likely eventually eliminate future downward vertical migration of contamination once water levels
stabilize in the Roubidoux Formation.

A numerical model was constructed for the Hematite Site by: (1) using the CSM to identify

hydraulic boundaries, (2) defining a suite of five layers corresponding to the shallow and deep overburden
and the three HSUs in bedrock, and (3) establishing the geometric (e.g., thickness and orientation) and

XX

R-d


April 21, 2008
To whom it may concern:

This statement is to explain how my employer monitored my exposure to radioactive
material during the time I was employed at the United Nuclear Facility at Hematite,
Missouri. Though my employment was from 1968 to (971, Twill
hereby address the period from . 968 throug 969.

I was provided with a dosimeter which I wore pinned to the front of my coveralls. The
patch it contained was collected periodically (possibly once a month.) I was never
informed of the results from testing of these patches.

At the end of each workweek I took home a specimen bottle, which I returned at the
beginning of the next workweek with a urine sample. J was never informed of the results
of those samples, if, indeed they were analyzed.

I was never tested for thorium or radon. J was never given a breath test.

T was sent to the comnanv doctor for a routine nhvsical exam annually.

porernally aporared vetore ie

om 4 2102 Al tuell

IKA NEWELL
Notaty Public - Notary Seal Public tov
Bale of MESON any N wi ‘
Cape iral
cor rigston Expires: Jly 01,2011 qe § ‘oa oy \

07167815

A-5


Mr, Ford defined fission products as “radioactive waste produced by a nuclear chain

reactions. ..[page214]

In a March 2001 report, the U.S. Department of Energy (DOE) announced that some of
the uranium that was enriched at Paducah, Oak Ridge, and Piketon had already been
fissioned in reactors used for the production of plutonium for nuclear weapons. This
uranium was called reprocessed or recycled uranium. Therefore, it is suspected that some
of the enriched uranium trucked into the Hematite plant may have contained neptunium,
plutonium, and other transuranic’s (extremely hazardous man made elements that are
heavier than uranium), as well as fission products, including technetium-99. (U.S.
Department of Energy, “A Preliminary Review of the Flow and characteristics of

Recycled Uranium Throughout the DOE Complex, 1952-1999.“

No one had even admitted that Paducah and other enrichment plants had worked with
materials from the back end of the fuel cycle (post-reactor fuel). In 2002 when residents
were notified about off site Twenty two private drinking water wells were identified as

being contaminated with volatile organic chemicals that had migrated from the Hematite
uranium plant via groundwater.

In addition to offsite. hazardous chemical contamination, radioactive technetium-99 was

detected in the evaporation ponds on site at the uranium plant in approximately 1976.

{EXHIBITA. 23-30 Letter}

Technetium-99, is a man made fission product created in nuclear reactor with a half life

of 211,000 years and is notoriously dangerous. “Technetium-99 has a specific activity of

4


environment, this concludes the Agencies demonstrated a fundamental disregard for the
devalue of human life, and a devalue of the employee’s families’ quality of life.
Can we really soundly, justify medical atrocities? We then justified this with the need to
protect the rest of us....
Can we now escape the responsibility to the workers of their personal safety, and security
of much needed medical treatments and compensatory remedies?
If so, it will be apparent the harm incurred by these nuclear workers to be an intentional,

deliberate, malicious aforethought if this petition is denied.

My final question is can your conscience, soundly escape them today having
the authority to right the wrongs that they themselves cannot? Or can you too justify it,
knowing we have and are “killing our own?”

We should make an honest effort to compensate these workers/victims of our nuclear
weapons production. They did their part to be faithful to us in the name of our national
security it is now our turn to be faithful to them.

It was the cold war workers who allowed us as a nation to maintain our safety and
because of that we gained, but with our gain they have lost. Lost their lives, quality of
life, health, and personal safety.

Las an American cannot forgo a scripture in Ecclesiastes
viii that clearly reminds me of our responsibility to them; “In the day of prosperity be

joyful, but in the day of adversity, consider.”

Please consider them now and grant this special exposure cohort.

THE FORMER WORKERS’ CLAIM FOR RELIEF

ie


concern” have been identified at the Hematite Site and include those locations where
these (and other) potential contaminants were stored, used, and/or disposed.”

{EXHIBIT’S 4-39-61}
CONCLUSION

Uranium and its daughter products have spilled, blown, been stored and been released
into the Hematite environment since 1956. No matter where the material has landed, it
will continue giving off (emitting) radioactive particles and rays for 4.5 billion years
times ten.

Most of the radioactive materials at the hematite Site give off alpha particles. If these

particles are inhaled or swallowed, they are at least 20 times more harmful than beta or

gamma emitters, (See the Nuclear regulatory Commissions table 1004(B).1 on
“Quality Factors” in Title 10, part 20 of the Code of Federal Regulations.

The workers at the Hematite site were also exposed non radioactive substances, such as
extremely hazardous volatile organic chemicals including but not limited to,
Trichloroethylene, perchloroethylene, and other volatile organic chemicals and were used
as cleaning agents sometimes to mop the shop floors.

Workers worked without protective clothing, monitoring, working equipment such as

hoods etc. and often wore their work clothes home thus, contaminating their homes and

families, (EXHIBIT A1-2, A-6, A-7 AFFIDAVITS and A-34}

i Dose reconstruction Overview by NIOSH{EXHIBITA-13} page 4 of 8


r e”” /o§

7 Was Employed hy

UM7ed Kubler. Was 2 Employ ee AF
HEMET ITE PeanT FRom )%2t- 1996s
Had AvNuak Fhy tial fq Company WoeToR.
Bul Keorved No Results 7AAT I REecsdda.
To my KNosledge Was WeveR LhEetK
for Kalua 2RE Thoroid, No Bre2xsh Tess
PRE pwleRwAL Monitoring. Bird HAVE URINE
Tés7. Mad Whole Bidgq fouwt YEAR KG «
Yad Hands bheak “pow Leave stg Pla ie
Some monthly Employces tad laws Keeget
ChELK And Mol High Mend W9 8, Had To
Wear Compamy Clethes Hoare.

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; Wale

& rs NOTARY", %
i: Jobherd’n Comey Miseoure
Comnmussion Zep 'lovizout

iti,  Youlyd Hizilo8
Waka

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‘S noraay 2
Sa
735081



PETITON FOR A SPECIAL EXPOSURE COHORT.
HEMATITE SITE
IN THE GREAT STATE OF MISSOURI

PETITONERS

UNITED STATES DEPARTMENT OF LABOR
UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES
NATIONAL INSTITUTE OF OCCUPATIONAL SAFETY AND HEALTH

RESPONDENTS

INTRODUCTION

This is a petition for a “Special Exposure Cohort” designation for the Hematite Site, in
the State of Missouri, which is a covered facility as an Atomic Weapons Employer as
defined in Section 3621 (4) of the Act which was contracted by the United States Atomic
Energy Commission and operated under the corporate name: United Nuclear Corporation

during the time frame of 1958-1969.

FACTUAL and PROCEDURAL BACKGROUND

1) In compliance with the Energy Employees Occupational Illness and Compensation
Program Act (42 U.S.C. 7384-7385), Public Law 106-398, that was enacted by congress
in 2000 establishes a program to provide compensation to individuals who developed

illnesses as a result of their employment in nuclear weapons production related activities


walkover survey results were used to locate surface sample locations for the RI; a comparison between the
areas with elevated gamma count rates and radiological analyses of surface samples is presented in Chapter 4

of this Ri report.

1.5.9 Determination of Distribution Coefficients for Radionuclides of Concern at the
Westinghouse Hematite Facility, July 2003

In July 2003, SAIC conducted a study to measure site-specific distribution coefficients for uranium
and Tc using soil collected from the Hematite Site (SAIC 2003c). A total of 18 soil samples were
collected from 6 borings that were advanced to refusal (assumed to be bedrock). Soil physical properties, as
well as isotopic uranium and “Tc activities, were measured in the soil samples prior to conducting the
distribution coefficient tests. The soil samples tested in the laboratory were representative of the brown silty
clay typically found in the shallow overburden at the Hematite Site. Uranium activities were detected at
elevated levels in samples from the restricted areas adjacent to the process buildings (>200 pCi/g total
uranium) and the shallowest sample collected from the Tile Barn/Cistern Burn Area (>34 pCi/g total
uranium). Except for one sample from the restricted areas, fc was not detected at concentrations greater
than the laboratory reporting limits in the samptes collected for the study. Results of this investigation are
described in Determination of Distribution Coefficients for Radionuclides of Concern at the Westinghouse
Hematite Facility (SAIC 2003c).

1.5.10 Wetlands and Surface Water Assessment

In preparation for the RI, a wetland and surface water assessment was conducted in November 2003
to delineate and classify potentially jurisdictional wetlands and surface water bodies at the Hematite Site
(SAIC 2004a). The assessment was conducted to identify potential impacts of Site investigation activities
(i.e., well installation and road building) with regard to compliance with requirements of Sects. 401/404
of the Clean Water Act. The single potential wetland identified at the Hematite Facility is located in a
small depression south of the Hematite Facility between the railroad berm and a gravel road that goes
from the vicinity of the Hematite Facility to the south towards Joachim Creek. The wetland is a small
isolated forested/scrub shrub wetland that is confined to the south and southwest by the gravel road and to
the north by the railroad berm. There were no inputs or outputs at the wetland and hydrology appears to
be the result of precipitation, which ponds between the road and railroad. A field survey of surface water
bodies within the Property was also conducted, and detailed descriptions of the intermittent streams were
performed, Based on the wetland and surface water survey, it was concluded that Site investigation.
activities can be implemented without significant impact to wetlands and surface water bodies.

1.5.11 Ongoing Environmental Monitoring Programs

Since 2002, quarterly groundwater monitoring samples have been collected from bedrock wells
BR-O1-RB, BR-02-RB, BR-03-RB, BR-04-RB, and BR-04-JC (see Fig. 1.2 for well locations) and
analyzed for VOCs and radiological contaminants. Groundwater samples have also been collected
periodically at private wells near the Hematite Facility; these private wells are shown in Figure 1.2 (labels
begin with "PW"). A discussion of these monitoring results is provided in Chapter 4 of this RI report.

As mentioned previously, the storm water and sewer water outfalls that discharge into the Site Pond
and Site Creek, respectively (Outfalls 1 and 3, see Fig. 1.3), are permitted under NPDES. As part of
permitting requirements, both of these outfalls and the surface water at Site Pond Dam (Outfall No. 2, see
Fig. 1.3) are monitored regularly for parameters required under the NPDES permit.

* The Hematite Facility operates under a Special Nuclear Materials (SNM-33) license from the
Nuclear Regulatory Committee (NRC). Following NRC license requirements, samples are routinely

1-12

Ae 54



Pits) and soil underneath process buildings, and even where migration to the subsurface has occurred,
there is little or no evidence of lateral migration away from these areas. Comparison of the uranium and
To groundwater data with chlorinated volatile organic compound (VOC) results indicates that the
radionuclides have not migrated as extensively as the VOCS.

Several sediment samples from Site Pond were found to contain significant contamination with
uranium and ”’Tc. However, Tc was not detected in any of the surface water samples from the Site.
Furthermore, uranium activities in surface water are elevated in the Site Pond but decrease significantly in
the Site Creek downstream of the Site Pond dam. These data suggest that there is no to minimal migration
of these radionuclides via surface water. me

The principal organic contaminants in sediment and soil are PCE and TCE. The distribution of PCE
and TCE in the groundwater and soil samples appear to reflect one or more source ateas associated with
the Hematite Facility and nearby disposal areas, although contaminated soils extend southeastward from
the Hematite Facility toward Joachim Creek and probably reflect migration of contaminated groundwater
from which sorption to soil organic matter has occurred. Dense, nonaqueous-phase liquid (DNAPL) was
confirmed at one location under a building at the Hematite Facility based on elevated concentrations of
PCE.

Contamination of groundwater with VOCs is widespread. PCE, TCE, and their degradation products
are commonly observed. A number of locations have sufficiently elevated PC ‘concentrations to
suggest the nearby presence of DNAPL. PCE and TCE plumes in the overburden originate at the Hematite
Facility and extend southeastward toward Joachim Creek. One component of contamination in the Jefferson
City-Cotter HSU has migrated in a southeasterly direction beneath Joachim Creek; a second component has
migrated down dip from the Hematite Facility towards the northeast. Decper contamination in bedrock only
has been confirmed in association with private wells PW-19, PW-16, and PW-06 in a residential community
to the southeast of the Hematite Facility across Joachim Creek and with PW-03 located east-northeast of the
Hematite Facility. PW-06, PW-16, and PW-19 are no longer used as domestic water supply wells and have
been converted to dual-completion groundwater monitoring wells as part of this RI.

Polycyclic aromatic hydrocarbons also are commonly found in surface and subsurface soil samples
from on-Site locations. They are common products of combustion of coal and other fuels, and also
frequently are associated with asphalt-paving material. Their presence is likely from one or a combination
of these sources. Localized occurrences of dioxin, polychlorinated biphenyls, and petroleum
contamination also were observed.

The presence of organic constituents in surface water is rarely encountered except for several low-level
detections of PCE and TCE downstream from the Hematite Facility. Methylene chloride was also detected
in a number of surface water samples but these detections were associated with method blanks, suggesting
that the results represent common laboratory contaminants rather than Site conditions.

Biological degradation of PCE and TCE is occurring at the Hematite Site, but appears not to have

proceeded past the production of 1,1-dichloroethylene (DCE); cis-1,2-DCE; and trans-1 »2-DCE, except in
relatively few samples.

xix

Ras



et eo.

GRASSLANDS ROAD
ELMSFORD, NEW YORK 10523
914.592.9000

HP. & NLS.
GROUP _ December 27, 1973
In reply, refer to MRA-73-298

U. S. Environmental Protection Administration

1735 Baltimore : ;
Kansas ‘City, Missouri 64108 a,

Attention: Permit Branch

Reference ~ Application No. MO-LMS~-OXL-2-000166

Gentlemen:

This is to advise you that Gulf Oil Corporation is divesting
itself of Gulf United Nuclear Fuels Corporation, a wholly-
owned subsidiary. As a result, it is our intention to shut-

. down the Company's plant at Hematite, Missouri in April 1974
and subsequently to decommission it. No liquid effluents are
anticipated to be discharged from the plant into Joachim Creek
following cessation of operations.

We believe it may be unnecessary, therefore, for you to pro-
cess our application for a permit. When Operations actually
cease next year, I shall advise you accordingly.

Sincerely, io,

i
PL:am . Peter Loyseh, Manager
Regulatory Administration

be: J. Brennan
D. Darr
J. Rosser

W-3}


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on



GAPING HOLE in Building 44
was blown out of the east wall.

TORNADO!

iwE TORNADO which hit
St. Louis on Feb. 10 left
its scars on many MCW
buildings — and a long list

of damages.

More than fifty buildings
sustained at least minor
damage. Hardest hit was
Building 44. (See pictures )

In other buildings win-
dows were broken, roofs
and doors were damaged,
guy wires were broken,
wall coping blown off.

Also much material was
damaged when the sprin-
Kler system broke in Build-
ing 43.

Luckily, rain preceded
the tornado instead of fol-
lowing it or material dam-
age would have been much
higher.

The MCW NEWS is published
bimonthly by the Mallinckrodt
Chemical Works for all person-
nel and their families.
Copyright, 1959
Mallinckrodt Chemical Works

from here and there

Editor
Bill Nunn

Editorial $.H. Anonsen M. I. Gould
Assit. Editor Photographer Advisory C.M. Bemis ©. M. Langenberg
Orval Heflin Charlie Graver Board D.M. Davis LH. Paxton

HARDEST HIT was Building 44 warehouse. These views
from Destrehan street show the south wall and window near
the west end where the tornado ripped into the fifth floor.

-3¥


Westinghouse Non-Proprietary Class 3

ts- E0-05-002

wet Remedial Investigation Report

For the Westinghouse Hematite Site
Rev 1, Volume 1: Text

Prepared for:

© westinghouse

Westinghouse Electric Company
Hematite Facility
3300 State Road P
Festus, MO 63028

Prepared by:

a re
An Enployae-Owned Company

Science Applications International Corporation
8421 St. John Industrial Drive
St. Louis, MO 63114
314-770-3000

and

GEO Consultants, LLC
199 Kentucky Avenue
Kevil, KY 42053
270-462-3882

January 2007

R-34


EO-05-002

Remedial Investigation
Report
For the Westinghouse
Hematite Site

Final Draft for Regulatory
Review
Rev 1, Volume 1: Text

Prepared for:

Westinghouse Electric Company
Hematite Facility
3300 State Road P
Festus, MO 63028

Prepared by:

Science Applications International Corporation
8421 St. John Industrial Drive
St. Louis, MO 63114
314-770-3000

and

GEO Consultants, LLC
199 Kentucky Avenue
Kevil, KY 42053
270-462-3882

January 2007

fle 40

Approved by:
James T. Cathoun
Missouri C.P.G. No. 2003012172

Approved by:
Gary M. Neutzling
Missouri P.E. No. 2003025983,


10. Past records indicate that beryllium was present at the Hematite Site. January 2007
Remedial Investigation Report Rev 1, Volume 1{EXHIBIT A-51}

11. There is belief that an investigation that an inclusion of a Be designation is warranted
for the Hematite Site. The Petitioners respectfully request the Department of Energy and
the Department of Labor to add a Be designation to the present AWE.

12. Petitioners respectfully request the National Institute of
Occupational Health give a favorable evaluation and award this Special Exposure Cohort
Petition for the Hematite Site.
13. Petitioners respectfully request that the above named agencies provide any further and
other relief that Jurisdiction, Act, Orders, or new information can allocate to
completely make provisions for all employees of the Hematite Site that deem just and

proper.

Respectfully Submitted this 13" day of June, 2008


Following the RI field activities, the data were integrated with available information from previous
investigations to develop:

° aCSM,

« an evaluation of the nature and extent of environmental contamination associated with historical
operations, and

« an assessment and prediction of contaminant F&T in the vicinity of the Hematite Site.
The Report is organized as follows:

* The remainder of Chapter | contains a history of operations at the Hematite Facility, descriptions of the
various buildings and areas on the Hematite Facility, a summary of previous investigations conducted
at the Hematite Site, and the areas of concern (AOCs) identified during these previous studies.

¢ Chapter 2 describes Site characterization activities performed during the RI.

« Chapter 3 presents the physical characteristics of the Hematite Site, including geology and
hydrogeology.

* Chapter 4 discusses the chemical characteristics of the Hematite Site, including nature and extent of
contamination.

* Chapter 5 describes likely sources of contamination, possible mechanisms for migration of
contaminants, a summary of groundwater and contaminant transport modeling results, and a
screening level assessment of monitored natural attenuation.

* Chapter 6 concludes the Report with a summary of major RI findings relevant to future feasibility
studies, remedial design and implementation, as well as long-term monitoring of surface water and
groundwater conditions in and around the Hematite Site.

* Appendices A through L provide supplemental and supporting information.

The groundwater and contaminant transport modeling conducted as part of the RI is described in
more detail in a separate report entitled Groundwater and Contaminant Transport Modeling for the WEC
Hematite Site (SAIC 2007); the full report is included in Appendix A of this report. Baseline health and
ecological risk assessment studies also will be covered in a separate document not included in this report.

on
1.3. FACILITY LOCATION AND HISTORY OF OPERATIONS

The Hematite Facility is located at 3300 Missouri State Road P in Jefferson County, Missouri, near
the town of Hematite (Fig. 1.1). The Westinghouse Hematite Property consists of 228 acres of land with
primary operations historically being conducted within the central portion of the property. Figure 1.2 shows
the approximate boundary of the Hematite Facility, encompassing the historic primary operations area, Site
Pond and burial pits.

Nuclear-related operations at the Hematite Facility began with the purchase of the Property (then

consisting of farmlands) by Mallinckrodt Chemical Works in 1955. The Hematite Facility became
operational in July 1956, producing uranium metals for the nuclear fuel program of the U.S. Navy.

1-3

f-G0


Special Exposure Cohort Td U.S. Department . Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
illness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Page 5 of 7

Basis for Proposing that Records and Information are Inadequate for Individual Dose —
Complete Section F.

Complete at least one of the following entries in this section by checking the appropriate box and providing
the required information related to the selection. You are not required to complete more than one entry.

F.4 ‘“ We have attached either documents or statements provided by affidavit that indicate that
tadiation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area
monitoring.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored.

S00 ottachoh

F.2 TM \/ We have attached either documents or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been lost, falsified, or
destroyed; or that there is no information regarding monitoring, source, source term, or process
from the site where the employees worked.

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
proposed class have been lost, altered illegally, or destroyed.

Ser—attechill

Name or Social Security Number of First Petitioner:



Special Exposure Cohort ran U.S. Department q = and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
ness Compensation Act National Institute for Occupational Safety and Health

- OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 4 of 7

Name of DOE or AWE Facility:
E.2 Locations at the Facility relevant to this petition:

FR, ONG ih nd

E.3 List job titles and/or job duties of employees included in the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you believe should be

included in this class: 1 . ‘
uN

an LA, ISB - NL U. i z/
Citininotion fbi rac G- Dt

E4 Employment Dates relevant’ to this petition:

stat LAS% End 149
stat 1470 end _Present
Start End
E.5 Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: Yes Q No

If yes, provide the date(s) of the incident(s) and a complete description (attach additional pages
as necessary):

See attach td detmenkS

Name or Social Security Number of First Petitioner:



and certain other federally-owned facilities in which radioactive materials were used.
The named Representativ has been authorized with signature by the

“Class” which is petitioning, with all rights as provided under 42 CFR Part 83, Section
83.7 (c)

2) As part of the Energy Employees Occupational Illness Compensation Act, on
December 7, 2000 the President of the United States issued Executive
Order No. 13179, and the Radiation Dose Reconstruction Rule (42 CFR 82);
Although, the National Institutes for Occupational Safety and Health’s (NIOSH) office of
Compensation Analysis and Support (OCAS) has the responsibility of completing dose
reconstructions using the methods described in the Radiation Dose reconstruction Rule

(42 CFR 82) it is the Department of Labor who makes the compensation decisions.

3) The Energy Employees Occupational Illness and Compensation Program Act (42
US.C.$$ 7384-7385 (EEOICA) authorizes the President to designate additional classes

of employees to be included in the (SEC).

HISTORICAL Background

As quoted in the Hematite Engineering Evaluation and Cost Analysis Response Action

for off site Groundwater Dated January 2003 page 3-4, section 2.1.1 site.

“The facility was opened in the mid 1950’s by Mallinckrodt Chemical Works and through
the mid 1970’s was owned and operated by a variety of entities, including United
Nuclear Corporation and Gulf Nuclear Fuels Company. Until the early 1970’s, the site
was heavily involved in producing uranium for the United States Navy and the Atomic

energy Commission. In the mid 1970’s Combustion Engineering Inc. acquired the

z


Spécial Exposure Cohort Td U.S. Sopanmon Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Illness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 7 of 7

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 300 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the
following:

The Energy Employees Occupational Illness Compensation Program Act (42 U.S.C. §§ 7384-7385)
(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Control and Prevention. Information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 09-20-147 “Occupational Health Epidemiological Studies and EEOICPA Program Records.
HHS/CDC/NIOSH.” These records are treated in a confidential manner, unless otherwise compelled by law.
Disclosures that NIOSH may need to make for the processing of your petition or other purposes are listed
below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
retrieve records required by NIOSH; (b) identified witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations;
(e) Federal, state and local agencies for law enforcement purposes; and (f) a Member of Congress or a
Congressional staff member in response to a verified inquiry.

This notice applies to alt forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these
forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Petitions that fail to
provide required information may not be considered by HHS.

Name or Social Security Number of First Petitioner:



collected for groundwater (nine wells), surface water (four locations), sediment (one location), surface
soils (seven locations), vegetation (four locations), and air (from three stack emissions) for gross
alpha/gross beta analysis (air samples are analyzed for gross alpha only). The license sampling also
includes the effluent sampling conducted under the NPDES permit.
16 AREAS OF CONCERN AND POTENTIAL CONTAMINANTS OF CONCERN

Records of historical operations at the Hematite Facility and results of previous investigations were used
to develop the following list of AOCs and associated RCOPCs and CCOPCs (Tables 1 and 2 of LBG 2003,
see Fig, 1.4 for map of AOCs):

¢ AOC #1 Groundwater (PCE, TCE and associated degradation products, fluoride, “*U, °U, ?4U, and
99
Tc),

* AOC #2 Surface Water Features (PCE, TCE and associated degradation products, fluoride, “°U,
2B35yy, 234Ep To, and 22TH),

* AOC #3 Burial Pits (PCE, TCE and associated degradation products, fluoride, **U, *5U, ?*U, °Tc,
and?’ Th),

« AOC #4 Evaporation Ponds (PCE, TCE and associated degradation products, fluoride, “*U, ?°U,
TMy, Te, and Th),

¢ AOC #5 Former Leach Field/Sanitary Sewer System ?°*Th, PCE, TCE and associated degradation
products, fluoride, **U, ?°U, *TM“U, and Tc),

¢ AOC #6 Soil Beneath Buildings (PCE, TCE and associated degradation products, fluoride, **U,
2351) 241) Te and 2327),

¢ AOC #7 Limestone Storage and Limestone Fill Areas ?*U, *5U, TMU, Tc, Th, and fluoride),

* AOC #8 Outdoor and Shallow Surface Area (PCE, TCE and associated degradation products,
fluoride, *5U, *5U, TMU, Te, and Th),

« AOC #9 Former Gas Station [PCE, TCE and associated degradation products, semivolatile organic
compounds (SVOCs), total petroleum hydrocarbons, and metals],

« AOC #10 Gas Pipeline (PCE, TCE and associated degradation products, fluoride, Tc, and Th),
¢ AOC #11 Red Room Roof Burial Area ?*U, *U, “U, Th, and fluoride),

* AOC #12 Domestic Well #3 (PCE and TCE and associated degradation products),

¢ AOC #13 Deul’s Mountain ?*U, ?°U, °“U, Th, and fluoride),

« AOC #14 Cistern Burn Pit Area (PCE, TCE and associated degradation products, SVOCs, metals,
dioxin, fluoride, °U, ?°U, **U, and ?Th), and


Buildings. Several buildings were used for various production operations and material storage. Brief
descriptions of the buildings, including historical and current use (as of the date this Report was
published), are given in Table 1.2, while building locations are shown on Fig. 1.3. In September
2004, WEC prepared an Engineering Evaluation/Cost Analysis (EE/CA, WEC 2004a) to evaluate
potential removal action alternatives for buildings and equipment at the Hematite Facility. The focus
of this EE/CA was on buildings that are radioactively contaminated or that can interfere with the
future characterization and, if necessary, remediation of impacted soil and/or groundwater beneath
the buildings.A Non-Time Critical Action Memorandum was issued in October 2005 documenting
the selection of equipement removal and building demplition as the preferred alternative for
remediation.

In advance of building demolition, the former process and storage buildings have been emptied of
equipment and materials involved in nuclear fuel production. The removed equipment and
materials have been packaged for shipment and sent off-Site for disposal or for metals reclamation.
At the conclusion of the equipment removal operations, Westinghouse conducted a final cleaning of
the buildings as needed to remove loose dust, dirt, and debris. This cleaning was performed by
vacuuming with units fitted with HEPA filtration systems. Following the cleaning, building surfaces
were surveyed and, a chemical fixative (“lock down” agent) was applied to the interior surfaces of
the radioactively contaminated buildings.

Spent Limestone Pile and Fill Areas. Hydrogen fluoride gas, a byproduct in the UF, conversion
process, was captured in limestone scrubbers during part of the plant history. Spent limestone was
generated from 1968 through 1998, when the limestone scrubbers were replaced with a more
efficient wet absorber system. Currently, the spent limestone is stored in surface piles within the
fenced area of the Hematite Facility. The spent limestone was also used as fill in at least two areas, one
near the Site Spring and the other northeast of the Burial Pits. The spent limestone was also used
historically as fill for building and road foundations. Figure 1.3 shows known locations of spent
limestone pile and fill areas.

Deul’s Mountain. An outdoor pile of potentially radiologically contaminated soil was located
southeast of Building 256 (Fig. 1.3). The pile of soil, referred to as Deul’s Mountain, came from
excavations during construction of Building 256. An EE/CA for removal alternatives was prepared
for this material in August 2004 (WEC 2004b) and approved by MDNR in January 2005. A Non-
Time Critical Action Memorandum approving excavation and off-Site disposal was signed in June
2005, and the material has been removed from the Facility.

“Red Room” Roof Burial Area. The roof of the “Red Room” of Building 240 was buried in an area
located south of Building 101 (the Tile Barn, Fig. 1.3). As noted in Table 1.2, Building 240 was used
for UFs conversion and the “Red Room” within this building was used for processing highly
enriched uranium. Soil contamination was discovered in 1993 during renovations to the Tile Barn
and was thought to be from use of this area for temporary scrap storage (Section 3.2.8, page 29 of
LBG 2003). Results of a geophysical survey performed in February 2005 detected magnetic and
conductivity anomalies in this area, indicative of a trenched or filled area. Details of the investigation
can be found in the document Geophysical Survey at the Westinghouse Hematite Facility, Festus, MO
(Geophex 2005), and the results are summarized in Sect. 2.8 of this RI report.

Cistern Burn Pit Area. The Cistern Burn Pit Area, also located south of Building 101 (Fig. 1.3),
was historically used to burn contaminated wood and pallets. Radiological contamination within the
cistern was reportedly removed in 1993 (Section 3.2.15, page 31 of LBG 2003) to less than 30 pCi/g
of uranium.

RSQ.



1.5.2 Preliminary Assessment Hematite Radioactive Site, Hematite, Jefferson County, Missouri,
Ecology and Environment, Inc., April 1990

Ecology and Environment, Inc. prepared a report for Region 7 of the U.S. Environmental Protection
Agency (EPA) that discusses the Hematite Site’s physical characteristics, potential waste sources,
surrounding residential areas and water sources, and groundwater and surface water characteristics
(Ecology and Environment 1990). The groundwater assessment was based on regional data and no new
field studies were conducted in preparation of this report.

1.5.3. Removal Action: Former Evaporation Ponds

Quadrex performed a radiological characterization of the former Evaporation Ponds in 1992
(Bicehouse 1992). Information gathered from this study was used to develop a source term for risk
evaluation. Because of the residual contamination present in the ponds, CE decided to remove soil from
the Evaporation Pond area. The material from the retention ponds was disposed at a low-level waste
disposal facility.

1.5.4 Investigation to Determine the Source of Technetium-99 in Groundwater Monitoring Wells
WS-17 and WS-17B, September 1996

Gateway Environmental Associates, Inc. conducted an investigation to determine the source of ”Tc
in overburden monitoring wells WS-17 and WS-17B (GEA 1996). Prior to this investigation, WS-17 had
been abandoned due to concerns that the well had a poor surface seal. WS-17B was installed in its place,
and subsequent groundwater sampling showed ”Tc activities to be consistent with activities measured in
WS-17,

A previous assessment had identified the Evaporation Ponds as a potential source of ”Tc
contamination in WS-17 and WS-17B. However, updated groundwater contour maps showed
groundwater flow directions that were inconsistent with this hypothesis, and that the more likely source
would be located north of WS-17 and WS-17B. Potential sources in this area were the spent limestone
pile, the uranium recovery area, and a former ring storage area (located immediately east-northeast of
Building 252, refer to Fig. 1.3). Twelve probe holes were drilled to approximately 15 ft deep in the
vicinity of these suspected sources. Subsurface soil samples from the probe holes and co-located surface
samples were analyzed for gross beta activity. Temporary groundwater monitoring wells were installed in
the probe holes, which enabled groundwater level measurements and the collection of groundwater
samples for gross beta and Tc analysis via liquid scintillation counting. These monitoring wells were
abandoned upon completion of the field investigation. Slug tests were conducted in WS-7 and WS-17B to
measure hydraulic conductivities.

Soil encountered in all the boreholes (approximately 15 ft deep) consisted of clayey silt overlying
silty clay. A highly plastic clay was encountered at the bottom of a few of the boreholes. Hydraulic
conductivities were measured at 0.33 fi/day (11.5 x 10° cm/sec) in WS-17B, and 0.06 fi/day
(2.2 x 10° cm/sec) in WS-7. The field hydrogeologist performing the slug test noted the presence of a
more conductive discrete zone within WS-17B at 8 to 10 ft BGS.

Based on the groundwater contour map constructed from water levels in the temporary wells,
Gateway Environmental Associates concluded that the Tc may have entered the groundwater system
within the former ring storage area and traveled downgradient toward WS-17/WS-17B. The distribution
of gross beta activily in the temporary wells generally supported this hypothesis, with gross beta activity
being highest directly underneath the former ring storage area. Gross beta activity in a few surface soil
samples from this area were also elevated; however, gross beta activity. in the subsurface soil samples

1-8

A-SS



reactor;
Production of highly enriched uranium metal for materials test reactors utilized by
the US Navy;
* Production of uranium-beryllium pellets for use in the SL-1, and experimental US
military nuclear power reactor that was part of the army nuclear power program;
Production of high enrichment uranium zirconia pellets for a naval reactor; and
Production of highly enriched oxides for use in general atomics nuclear rocket projects.

Although uranium material production was the primary function at the Hematite facility,
records indicate secondary activities such as uranium scrap recovery and a limited
amount of work with thorium compounds as part of early research into the use of thorium
in the fuel cycle. A detailed list of radioactive feed materials historically used for

production is not available.” [EXHIBIT A-51]

In 1990 the Environmental Protection Agency asked the National Academy of
Sciences to do a study on the health risks from exposure to low levels of ionizing
radiation. In 2006 the National Research Council published a report “BEIR VII”
Biological Effects of Ionizing Radiation which concluded that; “NO LEVEL OF

RADIATION IS SAFE”

was a security guard at the Hematite Site for approximately 21 years. One
cold night when all skilled plant personnel was scheduled off, a criticality occurred,
Apparently an anhydrous ammonia tank had leaked. Because was the only
employee on duty he was instructed by plant management to go and shut off valve, in
attempt to find shut off valve he was overtaken by toxic fumes. Because this direct order
was not an area of expertise or his normal job duties did not have any

protective clothing, masks, respirators, etc also made his daily rounds of


@ »

SPECIAL EXPOSURE COHORT PETITON
HEMATITE SITE
STATE OF MISSOURI
JUNE 13, 2008

06-19-0 8407:03 RCVD

PETITONERS


gradual, or the potential presence of fat clay lenses in the deeper silty clay layer. LBG concluded that the
fat clay layer could not be considered an aquitard because of its discontinuous nature. The
clayey/silty/sandy gravel unit was encountered (thickness ranging from 4 to 6 ft) in all boreholes that
were drilled to refusal or auger-drilled to bedrock. Note that all of these boreholes were drilled outside the
old fenced area of the Hematite Facility (see Fig. 1.2). Visual examination of the core from one of the
boreholes (WS-31, see Fig. 1.2 for location) drilled through shallow bedrock showed gray/tan, fine-
grained dolomite. No vertical fractures or joints were intersected by this borehole and bedding planes
appeared to be well-sealed. LBG concluded that storativity and transmissivity of the dolomite was from
bedding planes and fractures rather than the matrix. A potentiometric surface constructed for the deeper
silty clay/sandy-gravel layer indicated a groundwater flow direction generally toward Joachim Creek. A
separate potentiometric surface was developed for the near-surface silty clay layer, which indicated
multiple groundwater flow directions depending on location within the Hematite Facility.

Average hydraulic conductivities measured in the different HSUs were: (1) 3 x 10° cm/sec for the
near-surface silty clay, (2) 80 x 10° cm/sec for the deeper silty clay layer, (3) 600 x 10° cm/sec for the
sandy gravel layer (result from one well), (4) 1 x 10° cm/sec for unfractured bedrock, and
(5) 80 x 10° cm/sec for fractured bedrock.

With the exception of one blind duplicate sample, results of VOC analyses in soil samples showed
concentrations of perchloroethylene (PCE) that were near the detection limit (5 pg/kg). TCE was not
detected in any of the soil samples. The inconsistency between the duplicate samples (the blind duplicate
exhibited elevated levels of TCE and PCE) was attributed to sample heterogeneity or laboratory error. In
groundwater, TCE and PCE were detected at levels above 50 j1g/L in one bedrock well (WS-30, 430 and
350 pg/L, respectively; the piezometer wells were not sampled), and in one well screened within the
deeper silty clay and sandy gravel layers (WS-32, 20,000 and 4,400 j1g/L, respectively). TCE and PCE in
the rest of the groundwater samples were either below the detection limit of 5 pg/L or were less than
50 pg/L. The measured radiological activities were deemed to be approximately at background levels,
although a statistical analysis of the data was not conducted. VOCs were below the quantitation limit
(4 ue/kg) and radionuclide activity was not detected at levels above background in stream sediment
samples collected from two locations (one from the Site Creek downstream of the Site Pond dam and the
other from the Northeast Site Creek). PCE was detected near the detection limit (5 pg/L) in the surface
water sample collected from the Site Creek. VOCs were not detected in the other surface water samples
collected from Joachim Creek and the Northeast Site Creek. Polychlorinated biphenyls (PCBs) were not
detected in any of the surface water samples. The surface water samples did not exhibit levels of alpha,
beta, or gamma activities above background.

1.5.7 Interim Hydrogeologic Investigation to Support the Engineering Evaluation and Cost
Analysis for Response Actions for Off-Site Groundwater Quality, November 2002

In the summer of 2002, WEC retained LBG to perform an interim hydrogeologic investigation
(LBG 2002b) to address the detection of VOCs in a number of private water wells near the Hematite Site.
Contamination in these private wells was detected in December 2001, when the Missouri Department of
Health and Senior Services, upon request from MDNR, added VOCs to the suite of radiological analytes
that were normally included in their annual radiological monitoring program. The purpose of the interim
hydrogeologic investigation was to evaluate the extent and degree of impacted groundwater on an
expedited basis. The results of the study were used to evaluate and, ultimately, select a time-critical
temoval action to address the detection of VOCs in nearby private domestic water supply wells. The
investigation also addressed monitoring for future off-Site and vertical contaminant migration by
installing sentry wells.

1-10

A-59



‘ ®@

onenty,
3

= NIOSH Dose Reconstruction Activity Report, January 2006 Public Health Service
“ecg National Institute for Occupational Safety

and Health

Robert A, Taft Laboratories

4676 Columbia Parkway, MS C-45
Cincitmati, OH 45226-1998
Phone: 513-533-8426

Fax: 513-533-6840

January 25, 2006

This is your January 2006 Dose Reconstruction Activity Report. It has been sent to update you on the current status of
your case and dose reconstruction program. No response or action is required from you at this time. If you do not wish
to receive your Activity Report, please contact our office at 513-533-8426 and we will remove your name from
our report's mailing list.

Your Dose Reconstruction Activity Report has two parts. Part 1 contains information on the current status of your case.
This part of your report may remain unchanged if your case has not reached the next step in the dose reconstruction
process at the time this report was created. Part 2 is updated in each report to provide you with current information
about our dose reconstruction program.

Part 1; Individual Dose Reconstruction Case Status

Major Steps of the Dose Reconstruction Process

The major steps of the dose reconstruction process are listed in the left column. The date that each step occurred is
listed in the right column. An "N/A" under "Date Step Occurred" means that the step has not occurred yet.

Steps in the Dose Reconstruction Process Date Step Occurred

e Case Received from DOL: 04/26/2004

The Department of Labor (DOL) is responsible for this compensation program. Once a claim
has been filed, DOL must first determine if the period of energy employee's employment and
medical condition are covered under this compensation program. After DOL determines that a
claim involves a covered energy employee with cancer, DOL sends the case to NIOSH for
dose reconstruction.

« Acknowledgement Letter Sent: 05/03/2004

The letter lets claimants know that NIOSH received the case for dose reconstruction. The
letter includes the NIOSH Tracking Number and general information on dose reconstruction.

e Telephone Interview Conducted; 07/02/2004

The telephone interview provides claimants with the opportunity to inform NIOSH of any
additional information regarding the work history of the energy employee. When we reach the
point in our process when we are ready to conduct the interview, we will contact the claimant
to arrange a convenient date and time for the telephone interview. Prior to the interview, we
will send a detailed copy of questions to help the claimant prepare for the interview.

Mag


Special Exposure Cohort ran US. eh, Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
liiness Compensation Act National Institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B Appendix — Petitioner 2
Complete Section B if you are a Survivor or representing a S

Survivor Informati
B.1 Name of Survivor:

Mr./Mrs./Ms. First Name Middle Initial Last Name
B.2 Social Security Number of Survivor:
B.3 Address of Survivor:

Street Apt # P.O. Box

City State Zip Code
B.4___ Telephone Number of Survivor: )

B.5 Email Address of Survivor:

B6 Relationship to Employee: Q Spouse Q Son/Daughter Q Parent
Q Grandparent Q Grandchild

Employee Information — Complete Section C.

C.1 Name of Emplovee:

Mr/Mrs./Ms. rirst wame iigaie inital Last Name

C.2 Former Name of Employee (e.g., maiden name/legal name change/other):

Mr/Mrs./Ms. First Name Middle Initial Last Name
C.3 Social Security Number of Employee:

C4 Addrace af Emalauan (if tivinn\:

Street - Ant # P.O. Box

City * * State Zio Code
C.5 Telephone Number of Employee:
C.6 Email Address of Employee:

C.7_ Employment Information Related to Petition
C.7a Employee Number (if known):

C.7b Dates of Employment: _ Start 196 & End 2°26
C.7¢ Employer Name: United Myelewy Co (22 rai OK
C74 Work Site Location: KA Mallwekvodt Clewzel Hovks
1a, D0 Atowme neasees _enploy er) hemubkibe, WO

C.7e Supervisors Name: __

Name or Social Security Number of First Petitione


Special Exposure Cohort ran US. Sopantaon Wicarn and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Illness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Appendix — Petitioner 2

Use this Appendix for Petitioner 2.

This appendix form is to be used as needed. Petitioner 2, or his or her representative, should complete the
parts applicable to him or her.

Refer to the General Instructions on completing petitioner information for Parts A, B, or C.

If you need more space to provide additional information, use the continuation page provided at the end of
the form and attach the completed continuation page(s) to Form B.

Except for signatures, please PRINT all information clearly and neatly on the form.

Ik An Energy Employee (current or former), Start at C
If you are: |Q A Survivor (of a former Energy Employee), Start at B

QA Representative (of a current or former Energy Employee), Start atA

A_ Representative Information — Complete Section A if you are authorized by an Employee or
Survivor(s) to petition on behalf of a class.

A.1 Are you a contact person for an organization? 1 Yes (Go to A.2) Q No (Go to A.3)

A.2. Organization Information:

Name of Organization

Position of Contact Person

A3 Mama af Datitinn Danenoantation:
WILAVES2IMIS. PISt Wari nngae iva Last Name

A4  Attenn-
Strear ‘Ant P.O. Box
City ner tata Sin Bade

A.5 Telephone Number:
A6 — Email Address:

A.7 —'& Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization
form for this purpose is provided.

Name or Social Security Number of First Petitioner:



int Groundwater Monitoring Wells 17 and 178

@. . set Do Determine the Source of *Te \

4 The piles of scrubber gravel are unlikely to be the source of’ ® Tc contamination in the
WS17/WS17B area since they were placed there after the contamination was discovered
in RMC 9. Additionally, CE reports that facility personnel have performed leaching tests
on the recently placed scrubber gravel. The scrubber gravel appears to leach quantities of
*Tc which are significantly less than those found in the groundwater.

@ The source area does not appear to be from a constricted point source, rather is covers a
relatively large area. Therefore the area used to extract uranium from the cuno filters is
not a likely source.

4 The beta activity in the groundwater appears to be from a large area containing a soluble
source of ” Te,

5.1 POTENTIAL EFFECT of °Tc in GROUNDWATER

¢ Results of this subsurface and surface investigation indicate the location of the former
scrubber gravel storage and former ring storage area as the source of ° Tc found in
WS17(B). Because beta activity in WS17B is less than 1/3 of that found in GWE-1 0, which
is located in the former ring storage area, it is apparent that the beta activity in groundwater
diminishes rapidly away from the ring storage area.

# Single well hydraulic conductivity analysis performed by Gateway on WS17 B, combined
with groundwater hydraulic gradient information as, as well as, as specific stratigraphic and
lithologic information, strongly indicate that a hypothetical particle of groundwater has an
average linear velocity of approximately two feet per year in the vicinity of WS17B. Even
though it is 16 times less than. the gross beta activity in WS17B, there is elevated gross beta
contamination concentration in GWE-6, which is some two hundred fect plant south of
GWE-10.

© This indicates that ground water transporting the agent of f pross beta activity is
moving faster than the average liner velocity would suggest, implying that the agent

of gross beta activity i is probably being transported in a discrete hydrostratigraphic
-unitof higher relative permeability, perhaps a silt or sand lens.

¢ Even if the discrete flow path hypothesis factual, surrounding properties are protected by the
Joachim Creek. It is located plant south of WS17B and serves as, as a constant head
boundary; which acts as a shallow groundwater drain thus protecting surrounding properties
from migrating groundwater with remote potential of containing elevated gross beta activity.

¢ Based upon site specific groundwater flow information and groundwater quality data,
Gateway holds the opinion, that it is doubtful that elevated gross beta concentrations sourced
at the former ring storage area would reach Joachim Creek before diluting to background
concentrations.
30 pt

ABBIR-ABBPHL Page 19.


In addition to the above information, the record of the computer assisted telephone interview was
reviewed carefully by the dose reconstructor and considered in the dose estimation process.

Dose Estimate

External Dose

External dose is received from radiation originating outside the body and is typically measured
by dosimetry worn on the body. Such radiation doses may have been delivered quickly (acute
exposure) or slowly over the period of time that the employee was exposed (chronic exposure).

A dosimetry summary corresponding tc employment at United Nuclear
Corporation indicated his total measured whole body dose to be 0.330 rem. An external dose
summary for 1970 indicated that 0.120 rem of that exposure was received in 1970. The contract
period with the AEC ended in 1969; therefore, the dose from 1970 was subtracted from the total
whole body dose with the remainder included in his dose reconstruction. A correction factor of
20% was added to the recorded dose value to account for possible measurement error, For
claimant-favorability this exposure value was applied to one monitoring peric

‘st year of employment. To maximize the dose assigned, the remaining monitoring
periods throughout his employment were treated as if he were not monitored and assigned the
values provided in the Technical Basis Document.’ The maximum external penetrating exposure
values during operations and the residual exposure values from Technical Basis Document: Site
Profiles for Atomic Weapons Emplayers that Refined Uranium and Thorium, Appendix D, United
Nuclear Corp.” table D.2 were assigned for this dose reconstruction. These values were
developed based on the highest dosimeter reading found for a monthly exposure period at United
Nuclear Corporation, External electron radiation exposures were not evaluated in this
assessment due to the limited range of electrons in tissue.

Organ doses from photons were assigned as constant’ values in the claimant-favorable energy
range of 30-250 keV, with an organ dose conversion factor (DCF) based on the mode value for
Exposure to Organ Dose for the Anterior-Posterior exposure geometry for that energy range.

For the purpose of estimating probability of causation, the measured photon doses were assumed
to be acute and the assigned photon doses was assumed to be chronic.’

The total external radiation dose assigned to the urinary bladder was 0.995 rem.

Occupational Medical Dose
The dose received from diagnostic X-ray procedures that were assumed to be required as a

condition of employment was evaluated for the urinary bladder. Based on information in the
Technical Information Bulletin: Dose Reconstruction from Occupationally Related Diagnostic X-
Ray Procedures,® a medical X-ray procedure was assigned for each year of employment during the
contract period with the AEC.

The total medical dose assigned to urinary bladder was 0.075 rem.

DRAFT Page 5 of 8

h-}4


Burial Pit Area. The Burial Pit Area is located to the east-northeast of the Hematite Facility (Figs. 1.2
and 1.3). Unlined pits were actively used by previous owners from 1965 to 1970 for disposal of
uranium-contaminated materials and other wastes. Other undocumented excavations prior to 1965
may exist. Burial pit logbooks contain entries recorded during the operational period from July 16,
1965 to August 24, 1970 (Section 1.3, page 8 of WEC 2006). According to the logbook, 40 pits were
created and filled between 1965 and 1970. The primary waste types disposed of on-site included
various solids such as trash, empty bottles, floor tile, rags, drums, bottles, glass wool, lab glassware,
acid insolubles, and filters. Chemical wastes were also disposed of in the pits including hydrochloric
acid, hydrofluoric acid, potassium hydroxide (KOH), trichloroethene (TCE), alcohols, oils, and
wastewater. Based upon the logbook, the mass of uranium disposed in each pit varied, ranging from
178.08 grams to 801.8 grams.

Evaporation Ponds. The Evaporation Ponds are located on the southeast side of the
Hematite Facility, south of the process buildings and directly adjacent to and west of the Limestone
Storage Pile within the security area on the Site (Fig. 1.3). The ponds were historically used for the
disposal of water from cylinder washing potentially contaminated with TCE and technetium-99
(Te) (Section 2.6.2, page 15 of LBG 2003). These ponds also received effluent streams for the wet
conversion processes being performed in Building 240 (Section 3.2.6.1, page 23 of LBG 2003).
Based on aerial photography review, the Evaporation Ponds were constructed sometime after 1966
and before 1971. In 1992, soil was removed from the Evaporation Pond Area as described in Sect.
1.5.3.

Sanitary Sewage and Storm Water Systems, including the Former Leach Field. The current
sanitary system (Fig. 1.3) consists of drain lines from buildings, a sewage treatment plant, and a
pipeline that carries treated water from the sewage treatment plant to a permitted discharge point into
the Site Creek immediately below the Site Pond (Outfall No. 1, Fig. 1.3). The discharge is authorized
under a National Pollutant Discharge Elimination System (NPDES) permit issued by MDNR.
Sewage sludge is routinely dewatered and disposed of at the Envirocare of Utah low-level waste
disposat facility. Due to reduced operations at the Facility, sewage sludge has not accumulated
significantly and removal has not been necessary for quite some time. The sanitary system receives
water from sinks, toilets, showers, and drinking fountains. It also received pre-treated laundry water,
wastewater from a process water demineralization system, and water from laboratory sinks when the
Facility was operating. Prior to 1977, wastewater from the sewer pipelines drained into a septic tank
and leach field (see Fig. 1.3 for location); the latter is no longer in use since the new sanitary
treatment plant was installed. The storm water system consists of lines that collect water from the
roof and ground surface drains and then channel the collected water to a NPDES-permitted discharge
point upstream of the Site Pond dam (Outfall No. 3, Fig. 1.3). The Site Pond dam is considered as
Outfall No. 2 in the Hematite Facility’s NPDES permit.

Site Pond and Site Creek. The Site Pond and Site Creek are located west and southwest of the
Hematite Facility and receive NPDES-permitted discharge water from sanitary sewage and storm
water systems (Fig. 1.3). The Site Pond is also fed by a natural spring located on the north tip of the
Site Pond (Fig. 1.2). The Site Creek merges with the Lake Virginia tributary, and the combined
stream discharges to Joachim Creek (Fig. 1.3).

Northeast Site Creek. This is an intermittent stream that runs parallel to the northeast boundary of
the Hematite Facility (Fig. 1.2).

Former Gas Station. This abandoned gas station is within the Hematite Site Property boundary located

approximately 1500 ft east of the Hematite Facility along Missouri State Road P (see Fig. 1.2). A
550-gallon single-walled steel underground storage tank was removed in May 2003 (Civil and

1-6

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4 Cosetol ap peeh ty Chan. . Hpwen. She. S34f of those vwoho Ao

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NIOSH Dose Reconstruction Activity Report @ : @ Page 2 of 3

« Summary Report from Interview Sent: 07/06/2004

After the telephone interview has occurred, a summary report of the interview is sent to the
claimant, The claimant is asked to review the report and provide comments and additions if
necessary.

e Conflict of Interest Letter Sent: N/A

This letter will be sent to the claimant explaining our Conflict of Interest Policy—that a dose
reconstruction will not be assigned to a Health Physicist who worked at the same covered
facility as the energy employee represented in the case.

© Case Assigned to Health Physicist for Dose Reconstruction: ; NA

This indicates the date that NIOSH assigned the case to a Health Physicist for dose
reconstruction. Once the dose reconstruction is completed for a case, a draft report is sent to
the claimant. Once the draft dose reconstruction report has been sent, claimants will no longer
receive a Dose Reconstruction Activity Report.

Employment and Exposure Information

‘The table below provides information on when a request for the energy employee's exposure monitoring records was
submitted and when NIOSH received a response to the request for records. Under the "Employer Accepts Requests for
Exposure Monitoring Information" section, there may be a "No" listed. "No" can mean:

1. The employer does not accept requests because it does not have any exposure monitoring information.
A point of contact for obtaining the exposure monitoring information has not or cannot be established with the
employer.

3. NIOSH already has possession of all monitoring information.

Date Exposure
Monitoring Response
Received

Employer(s) Employer Accepts Request for | Date Request for Exposure
Verified By DOL |Exposure Monitoring Information| Monitoring Information Sent

*United Nuclear

Corp. No N/A N/A

*Hundreds of thousands of documents have been collected that may contain information on the worksite(s) indicated
above (*). In an effort to sort through this information in a timely manner, NIOSH has hired a contractor specifically
dedicated to analyzing these documents over the next year. During this time, if the documents can be used to complete
dose reconstructions for the worksite(s) identified with an *, we will begin working on the dose reconstruction. If at
any time the contractor or NIOSH determines that there is not enough worksite or personal monitoring information
available to complete your case, we will notify you that a dose reconstruction cannot be completed and your case will
be referred to DOL for a decision without a dose reconstruction. NIOSH will also discuss with you other options for
seeking possible compensation that do not require a completed dose reconstruction,

NIOSH Tracking Number: 016152

Ar



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much. specuttionr~ as te whe. ALLURALY Yf These, badges,

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A ink rhe werkers Aal fe ge wecks da Lab be get

Phastic. bags which Com tamil jeltas and Containtes
Pf Akadium to fe Fitna Crem ted. Y
vr /


JIM RODE, assistant manager of research and develop-
ment, checks an instrument panel in the pelleting plant,

ah. Fae i ae a

THIS MACHINE, inspected by Dr. Bill Tompkin, research and devel-
opment manager, grinds pellets to five ten-thousandths of an inch.

Nee

IN THIS sintering furnace pellets are heated at 3000 degrees Fahrenheit. Tom Knox (left), a chemical engineer, watches young Bill
Taylor, also a C. E., carefully pull out a tray of the hot pellets. The facility’s first production will go to a new experimental reactor.

.+- receive a license from the AEC to convert uranium
hexafluoride.

.+-receive a permit from the Bureau of Explosives
covering the design of shipping containers accept-
able to the Bureau and Interstate Commerce Com-
mission.

... manufacture and ship uranium metals and com-
pounds both domestically and in export.

... develop processes for materials with special physi-
cal characteristics such as uranium dioxide “shot,”
tiny pieces of uranium dioxide fired at a high tem-
perature.

Now, after some two and a half years and with the
industry’s most modern and automated facility for pro-
ducing uranium pellets, Mallinckrodt Nuclear Corpora-
tion looks to the industry's future.

“The long range picture is good,” says Horton, “It’s
primarily a question of time until improvements cut
costs. Especially interesting now, as a weathervane for
the future, is the performance of the Commonwealth
Edison plant near Dresden. This is the first big reactor
built by private industry and it may point the way the
industry will go in the important years ahead.”

Mallinckrodt will play a big part in the way the indus-
try goes. With our entry into fuel fabrication, the Com-
pany as a whole is now involved in four of the six steps
in atomic fuel production,

In step one, we furnish some crude uranium, extracted
from euxenite ores.

At Weldon Spring, in step two, we refine a large por-
tion of all the uranium used in this country by reactors.

This refined uranium is enriched at one of the AEC’s
specialized plants (chiefly Oak Ridge) in step three.

Mallinckrodt comes in again on the fourth step with
fuel preparation at Hematite and on the fifth step with
fuel fabrication,

The sixth step is reactor design, construction and oper-
ation, which others do.

As President Fistere said, “The Hematite plant attests
Mallinckrodt’s confidence in the future of the commercial
nuclear power industry, Although the industry is still in
its infancy, rapid expansion should materialize after ex-
perience proves the economy of nuclear power. Mallin-
ckrodt is prepared to meet this expansion at Hematite
and is committed to a policy of constructing additional
facilities when the demand warrants such expansion.”

39


Special Exposure Cohort ran U.S. Department 95 and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
I'ness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Page 6 of 7

F.3 O IMWe have attached a report from a health physicist or other individual with expertise in
radiation dose reconstruction documenting the limitations of existing DOE or AWE records on
radiation exposures at the facility, as relevant to the petition. The report specifies the basis for
believing these documented limitations might prevent the completion of dose reconstructions for
members of the class under 42 CFR Part 82 and related NIOSH technical implementation

guidelines,
(Attach report to the back of the petition form.)

F.4 0 IMWe have attached a scientific or technical report, issued by a government agency of the
Executive Branch of Government or the General Accounting Office, the Nuclear Regulatory
Commission, or the Defense Nuclear Facilities Safety Board, or published in a peer-reviewed
journal, that identifies dosimetry and related information that are unavailable (due to either a lack
of monitoring or the destruction or loss of records) for estimating the radiation doses of
employees covered by the petition.

{Attach report to the back of the petition form.)

All Peti*’- ~*~" * *** ee persons may sign the petition.

: Date

; — “2 #F-8 7
' Date
: a #-O7_
: Date

Notice: Any person who knowingly makes any false statement, misrepresentation, concealment of
fact or any other act of fraud to obtain compensation as provided under EEOICPA or who
knowingly accepts compensation to which that person is not entitled is subject to civil or
administrative remedies as well as felony criminal prosecution and may, under appropriate
criminal provisions, be punished by a fine or imprisonment or both. | affirm that the information
provided on this form is accurate and true.

Send this form to: SEC Petition
Office of Compensation Analysis and Support
NIOSH
4676 Columbia Parkway, MS-C-47
Cincinnati, OH 45226

Name or Social Security Number of First Petitioner:



62,000,000 Becquerel per gram. Activity of this level must not be allowed to spread.

Technetium-99 is a contamination hazard and should be handled in a glove box. "CRC

Handbook of Chemistry and Physics, 82"! edition, 2001-2002 page 4-30)
The presence of technetium-99 at the Hematite site is proof that the Paducah materials
had already been in a reactor because Technetium-99 does not exist in nature, Plutonium
and other transuranics were no doubt also present in the uranium hexafluoride that was

received at Hematite from Paducah..
Many of the workers at the Hematite site worked bare handed without proper protective
masks, clothing, gloves, and other protective equipment ete.

{EXHIBIT A-2, A-34}

Quoting from a NIOSH_ Report of Dose Reconstruction approved on 4-8-2008 from the

Office of Compensation Analysis and Support (OCAS) prepared for

page 2 of 8 states as follows:
“Even in instances when radiation dosimetry data are available, they rarely specify dose
to an organ and are often based on monitoring \procedures that do not meet modern
standards.” {EXHIBIT A-11}

Quoting from the Remedial Investigation Report for the Westinghouse Hematite Site Rev

1, Vol 1: text, January 2007, Executive Summary page xvii, paragraph 4,states as

follows:” evaporation ponds and the burial pits include strong mineral acids
(hydrochloric, hydrofluoric, and nitric)) and chlorinated organic solvents

perchloroethylene (PCE) and trichloroethylene (TCE). A number of potential “areas of

5



Environmental Consultants, [nc. 2003). No associated soil removal was required based on analytical
results being below MDNR cleanup guidelines for benzene, toluene, xylene, methyl-t-buty! ether,
and total petroleum hydrocarbons. No groundwater was encountered during excavation.

¢ Railroad and Gas Pipeline. Railroad tracks and a high-pressure gas pipeline (approximately 4 to
5 ft deep) cut through the Hematite Site southeast of the Hematite Facility. It has been suggested that
the pipeline may be acting as a conduit for contamination transport in the subsurface. During the RI
field investigation, excavations to expose the pipeline indicated that the pipeline was not buried in a
gravel bed. The materials surrounding the pipeline consisted of native soil. The pipeline depth
ranged for 3 to 5 ft below ground surface (BGS).

« Joachim Creek and Bridge. This perennial stream runs approximately 800 ft southeast of the
Hematite Facility (Figs. 1.1 and 1.2) and eventually discharges into the Mississippi River near the
city of Herculaneum, approximately 9 to 10 miles from the Hematite Facility. There were verbal
reports of third-party waste disposal activities in the vicinity of Joachim Creek Bridge (Section
3.2.16, page 31 of LBG 2003). .

1.5 PREVIOUS ENVIRONMENTAL INVESTIGATIONS AND ONGOING MONITORING
PROGRAMS

Brief descriptions of previous investigations are given below, while more details can be found in the
referenced reports. Note that additional investigations may have been conducted previously at the
Hematite Site. However, reports are only available for the investigations described in the following
sections. Comparisons are made between the results of these previous studies and the RI in Chaps. 3
through 5 of this report.

1.5.1 Radiological Survey of the Combustion Engineering Burial Site, July 1983

Radiation Management Corporation, under contract to the Nuclear Regulatory Commission,
conducted a radiological survey of the Burial Pits in the spring and summer of 1982 (RMC 1983).
External radiation levels were measured and samples were collected to determine radionuclide
concentrations in air, groundwater, and surface water. Results of the external radiation surveys indicated
detectable levels above background in the northwest corner of the Burial Pit Area adjacent to the old
security fence. It was determined that these levels were due to containers of UF, routinely stored in an
area next to the fence line rather than buried material. Results of surface soil sampling indicated low-level
surface contamination that may have resulted from past burial activities or from airborne (i.e., stack)
releases. Activities for “U ranged from 2 to 47 pCi/g, as estimated from 28U activity that ranged from
1.7 to 4.9 pCi/g, and assuming an activity ratio of 10. The activity ratio was estimated from a 4% average
enrichment in five samples that were analyzed for isotopic uranium using alpha spectroscopy. Results of
subsurface soil sampling (deepest sample at 13 ft) showed the highest *“U activity in the Burial Pits was
approximately 400 pCi/g, as estimated from measured TM*U activity of 38 pCi/g and a UU activity
ratio of 10. In the groundwater and surface water samples, only one groundwater sample collected from a
borehole showed gross alpha activity exceeding 15 pCi/L (the drinking water limit at the time). Gross
beta activity exceeding 50 pCi/L was found in 5 of the 22 samples, 3 of which came from a borehole near
the Evaporation Ponds. High volume air samples collected in the vicinity of the Burial Pits showed no
unusual or elevated levels.

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Mallinckrodt Chemical Works and related entities operated the Hematite Facility until 1961, when
ownership was transferred to a joint venture called United Nuclear Corporation (UNC). UNC continued
to produce uranium products for the Federal government. In 1971, UNC and Gulf Oil Corporation (Gulf)
entered into a joint venture forming the Gulf United Nuclear Fuels Corporation, which owned and
managed the Hematite Facility until January 1974. General Atomic Company (GAC), a partnership
involving Gulf, owned the Hematite Facility from January 1974 through May 1974, when Combustion
Engineering Inc. (CE) purchased the Hematite Facility from GAC. Asea Brown Boveri (ABB) purchased
the stock of CE in 1989, and CE began operating the Hematite Facility as ABB Combustion Engineering,
In April of 2000, WEC purchased the nuclear operations of ABB, which included the Hematite Facility.
WEC ceased operations in June 2001 and is proceeding with Site investigation activities in preparation
for Site remediation, including decommissioning.

Throughout its history, the manufacture of uranium metal and compounds from natural and enriched
uranium was the primary activity at the Hematite Facility (Section 2.2, page 4 of LBG 2003). Operations
included the conversion of uranium hexafluoride (UF) gas of various “°U enrichments to uranium oxide,
uranium carbide, uranium dioxide pellets, and uranium metal. During the period prior to the purchase of
the Property in 1971 by Gulf United Nuclear Fuels Corporation, classified government projects
dominated Hematite Facility operations. As such, specific details regarding the exact nature of production
processes prior to 1974 are not known. The following are examples of known projects during this time
(Section 2.2, page 4 of LBG 2003):

¢ — production of uranium metal for use in the U.S. Navy’s nuclear-powered submarines and destroyers;
¢ production of specialized uranium oxides for use in the U.S. Army’s Army Package Power Reactor;
¢ production of highly enriched uranium oxides for a General Atomics gas-cooled reactor;

* production of highly enriched uranium metal for materials test reactors utilized by the U.S. Navy;

* production of uranium-beryllium pellets for use in the SL-1, an experimental U.S. military nuclear
power reactor that was part of the Army Nuclear Power Program;

* — production of high-enrichment uranium zirconia pellets for a naval reactor; and
* production of highly enriched oxides for use in General Atomics nuctear rocket projects.

Although uranium material production was the primary function at the Hematite Facility, records
indicate secondary activities such as uranium scrap recovery and a limited amount of work with thorium
compounds as part of early research into the use of thorium in the fuel cycle.

A detailed list of radioactive feed materials historically used for production is not available.
However, previous investigators have compiled a list of chemicals (Table 1.1) used at the
Hematite Facility during active operations (Section 3.2.6.2, page 26-27 of LBG 2003).

1.4 DESCRIPTION OF THE WESTINGHOUSE HEMATITE FACILITY AND SITE

The Hematite Site and Facility contain features shown on Figs 1.2 and 1.3, respectively, and briefly
described below (based on Section 3.2, pages 20-31 of LBG 2003). The “fence line” as used in this Report
refers to the “old” fence line, and not the new security fence installed in 2004. The old fence line is shown
on all the figures in this report.


Bedrock cores were collected from the formations underlying the Hematite Site including the
Jefferson City-Cotter Formation, the Roubidoux Formation, and the top of the Gasconade Formation (in
order of increasing depth, more details regarding Site geology are presented in Chapter 3). The bedrock
borehole locations (BR-01 through BR-04) are shown in Fig. 1.2. The geology and hydrogeologic
properties of the bedrock underlying the Site were evaluated through various geophysical tests and video-
logging. Vertical profiling of groundwater quality was accomplished by collecting discrete groundwater
samples from packer-isolated intervals within the bedrock boreholes. In addition, two overburden
boreholes were drilled at two locations along the natural gas pipeline (OB-01 and OB-02) to address
concerns that this pipeline was acting as a conduit for off-Site contaminant migration. Monitoring wells
were installed in the overburden borehole locations (OB-01 and OB-02) and in BR-03, where analysis by
a mobile laboratory indicated the presence of PCE in an overburden soil sample from this location. Wells
screened in the Jefferson City-Cotter and the Roubidoux Formations were installed in the bedrock
borehole locations; bedrock wells were not installed in the Gasconade Formation because contamination
was not detected in any of the groundwater samples collected during sampling of packer-isolated
intervals. Bedrock monitoring wells were installed in the Jefferson City-Cotter Formation at BR-01, BR-02,
and BR-04. Bedrock monitoring wells were installed in the Roubidoux Formation at BR-01 through BR-04
(see Appendix D for well construction data for all wells installed at the site). Potentiometric maps were
prepared from water level measurements in the newly installed bedrock wells.

The geologic character of the overburden was consistent with the previous investigation (Section 4.2,
pages 9-13 of LBG 1999), An anomalously deep overburden/bedrock interface was noted in BR-04 (~50-
fi depth, compared to 30 to 35 ft within the Hematite Facility). Rock quality and permeability showed a
wide range of results even within the same formation; no consistent trends or patterns were noted. Based
on potentiometric maps developed for the Jefferson City and Roubidoux Formations, groundwater flow
was predominantly to the east. Calculated hydraulic conductivities from the slug tests were reported,
although some of these values are suspect due to problems with the drawdown analysis or with the
drawdown data (see Chapter 3).

VOC analyses by a mobile laboratory indicated low levels (approximately 4 g/L of TCE,
approximately 12 jg/L of PCE) in groundwater from the overburden well at BR-03. TCE and PCE were
not detected in the other overburden wells (OB-01 and OB-02) and in an overburden groundwater sample
collected from BR-04. During groundwater sampling from packer-isolated intervals in bedrock at BR-01
through BR-04, VOC contamination was only detected in BR-04 at the 95- to 105-ft-BGS depth interval
(within the Jefferson City-Cotter Formation). This was confirmed by analysis of a groundwater sample
collected from the bedrock monitoring well subsequently installed and screened within this interval.
Contamination in the deeper Roubidoux and Gasconade Formations was not detected in any of the
bedrock borehole locations during this study.

Gross alpha and gross beta activities were measured in soil samples collected from the overburden.
The data were presented but not discussed due to the lack of information regarding background activities.
Gross alpha, gross beta, total U, and *’Tc activities were measured in groundwater samples from the
overburden and bedrock. Technetium-99 was below detection limits (approximately 2 pCi/L) in all
groundwater samples. Maximum gross alpha, gross beta, and total uranium activities in filtered
groundwater samples were 64.7, 118, and 28.7 pCi/L, respectively.

1.5.8 Gamma Walkover Survey, April 2003
A gamma walkover survey (SAIC 2003a) over the entire Hematite Facility and large areas within the
Hematite Site was conducted in April 2003 by SAIC. Areas with elevated gamma count rates were consistent

with AOCs that had been previously identified (Section 3.2, pages 20-31 in LBG 2003, and Sect. 1.6 of this
report). Thus, the survey did not reveal any new surficial sources of radiological contamination. The gamma

I-11

hoo



4006 Federal Register/Vol. 66, No. 11/Wednesday, January 17, 2001/Notices
Jurisdiction Facility name Location Facility type

International Register Chicago AWE
Kaiser Aluminum Corp. Dalton AWE
Lindsay Light and Chemical Go. W. Chicago AWE
Madison Site (Speculite) .. Madison AWE/DOE
Midwest Manufacturing Co. Galesbury .. AWE
Museum of Science and Industry Chicago AWE
National Guard Armory Chicago AWE/DOE
Podbeliniac Corp. Chicago AWE
Precision Extrusion Co. Bensenville AWE
Quality Hardware and Machine Co. Chicago AWE
R. Krasburg and Sons Manufacturing Co. Chicago AWE
Sciaky Brothers, Inc. Chicago AWE
Swenson Evaporator Co. AWE
Unwersity of Chicago AWE/DOE
W.E. Pratt Manufacturing Co. AWE
Wycoff Drawn Stee! Co. AWE
American Bearing Corp. AWE
Dana Heavy Water Plant... DOE
General Electric Plant .. AWE
Joslyn Manufacturing and Supply Co AWE
Purdue University Van der Graaf Lab AWE
Washrite .. AWE
Ames Laboratory DOE
lowa Ordnance PI: Burlington .. DOE
Titus Metals: Waterloo AWE
Spencer Chemical Co., Jayhawks Works .. Pittsburg AWE
Paducah Gaseous Diffusion Plant Paducah DOE
Eniwelok Test Site Marshall Islands DOE
Armco-Rustless iron & Steel Baltimore AWE
W.R. Grace and Company Curtis Bay AWE/DOE
American Potash & Chemical §.. West Hanover AWE
C.G. Sargent & Sons Graniteville . AWE
Chapman Valve ... Indian Orcharc AWE/DOE
Edgerton Germeshausen Boston AWE
Fenwal, inc. . Ashland AWE
Franklin Institute .. Boston BE
Heald Machine Co. Worcester AWE
La Pointe Machine and Tool Co. Hudson AWE
Massachusetts Institute of Technology Cambridge . AWE/BE
Metals and Controls Corp. Attleboro AWE
National Research Corp. Cambridge . AWE
Norton Co. .... Worcester AWE/BE
Nuclear Metals, Inc. Concord AWE/BE
Reed Rolled Thread Co, Worcester AWE
‘Shpack Landfill Norton .. AWE/DOE
Ventron Corporation Beverly AWE/DOE
Winchester Engineering and Analytical Center Winchester ..
Woburn Landfill Woburn
Wyman Gordon Inc.
AC Spark Plug ..
Baker-Perkins Co,
Carboloy Co.
Extruded Metals Co. Grand Rapids
General Motors Adrian .
Gerity-Michigan Corp. Adrian ..
Mitts & Merrel Co. Saginaw
Oliver Corp. ... Battie Creek
Revere Copper and Brass Detroit
Speed Ring Experimental & Tool Company Detroit
Star Cutter Corp. .. Farmington ..
University of Michigan Ann Arbor ..
Wolverine Tube Division Detroit
Elk River Reactor Elk River ..
Salmon Nuclear Explosion Hattiesburg ..
Kansas City Plant ... Kansas City
Latty Avenue Properties .. Hazelwood
Mallinckrodt Chemical Co., Destrehan St. Plant St. Louis
Medart Co. St. Louis
Roger Iron Co.
Spencer Chemical Co.
St. Louis Airport Site
Tyson Valley Powder Farm
United Nuclear Corp. Hematite
Weldon Spring Plant Weldon Spring

hl

O


MCW’S TWO-MILLION-dollar investment in the commercial nuclear industry nestles among foothills forty miles from St, Louis.

division. (This became the Mallinckrodt Nuclear Corpo-
ration this year.) In September of 56 the Hematite plant
completed the world’s first private industry production
of enriched uranium oxide for commercial electrical
power. (MCW News, November-December, 1956.) ‘Let’s
go sine with the visiting Frenchman to see how this
MCW “baby” has grown since we saw it launched more
than two years ago.

In the office we meet Dr. Ed North, plant manager.
Since the first run in the fall of 56, he tells ws, the plant
has processed some 200,000 pounds of enriched uranium

compounds for some eighty customers. This has fueled .

nuclear reactors in the United States and fifteen coun-
tries around the world — Argentina, Australia, Austria,
Belgium, Brazil, Canada, Denmark, Italy, Japan, Norway,
South Korea, Sweden, Switzerland, West Germany and
Vietnam.

From this plant, Horton adds, came all the fuel for the
Pacific Gas and Electric Company's prototype power plant
outside San Francisco. Hematite has processed fuels for
experimental uses in connection with the power projects
of the Yankee Atomic Power Company at Rowe, Mass.,

~Consolidated Edison, New York, and Detroit Edison.

It is now processing all of the fuel for the first core
of the Commonwealth Edison full-scale power plant at
Dresden, Il., near Chicago. It is producing pellets for
the Northern States Power Company experimental reactor
being built by Allis-Chalmers.

And it is shipping enriched uranium dioxide for fuel-
ing the world’s first nuclear merchant ship, the N. S.
(Nuclear Ship) Savannah. The Savannah, a keystone of
President Eisenhower’s atoms-for-peace program, will be

Jaunched this spring arid commissioned in the summer
of 1960 for world-wide maritime service.

Our plant visit starts in the locker room of the main
building where we put on the customary long white
coats and rummage through assorted overshoes to find
the right size, First stop is the Red Room. (Areas are
designated by color to help prevent cross mixing of
various enrichments.) High enrichment uranium is proc-
essed here to make metal or oxides.

We watch the operators start with green salt (uranium
tetrafluoride). With other compounds, this is loaded in
a crucible which goes into a reduction bomb. The bomb
is fired in an induction furnace, and the uranium metal
settles to the bottom of the crucible.

In here, too, are small areas for production of uranium
dioxide, uranyl sulfate and for processing scrap with
high enrichment uranium.

Down the hall is the Green Room. This is strictly for
production of low enrichment compounds, This is where
the main valume of production is now coming from.

On into the Blue Room we go. Here is the middle en-
richment processing line and another recovery unit for
low enrichment scrap, The section over to the right con-
tains facilities for research and development.

We head outside now. The spring air is crisp, Dr.
North points out the fringe of trees in the distance. Little
Joachim Creek wanders through there. You wonder if
the fish are biting.

Next stop is a long, narrow building. Here is stored
the plant’s main raw material—UF, or uranium hexa-

(Continued on next page)

A-3S


. X DEPARTMENT OF @.., & HUMAN SERVICES Pubic Health Service

National institute for Occupationat
Safety and Health

Robert A Taft Laboratories

4676 Columbia Parkway

Cincinnati, OH 45226-1998

Phone: 513-633-8426

Fax: 513-533-6840

March 27, 2008

As the Public Health Advisor assigned to your case, | would like to update you on the current status of
the claim you filed under the Energy Employees Occupational Illness Compensation Program Act
{EEOICPA). The National institute for Occupational Safety and Health (NIOSH), Office of
Compensation Analysis and Support (OCAS), has recently reviewed your claim file and determined
that sufficient information has been gathered from the available records sources and we can now
begin the dose reconstruction for your claim.

To avoid the potential for actual or perceived conflict or bias issues in our dose reconstruction effort,
we have established a policy of selecting a Health Physicist(s) to work on the dose reconstruction for
your claim that was not involved in dosimetry or dose reconstruction in the site(s) represented in your
claim. A copy of our Statement of Policy, its implementation plan, and staff Conflict or Bias Disclosure
Statements can be found on our Web site at’ hitp www html, or can be
obtained by calling me at the number listed below.

Once the dose reconstruction report is completed, you will receive a copy of the report for your review
and have an opportunity to comment on the report at that time.

\f you have any additional questions regarding your claim, please feel free to contact me or my team
at 513-533-8426 | can alsc be contacted through the NIOSH OCAS email address: ocas@cde.gov.
Additional information on 0/2AS can also be found on our Web site at httoy iost

Sincerely yours,

April Jenkins

Public Health Advisor

National Institute for Occupational Safety and Health (NIOSH)
” Office of Compensation Analysis and Support

1-800-232-4636

A-¥



hydraulic properties for cach layer. The flow model was calibrated against water level data obtained
during the RI (i.e., following shutdown of both the private residential and Festus city wells). The principal
conclusions from the modeling investigation include:

The shallow groundwater mound in a localized area (northeastern corner) of the Hematite Facility
plays a major role in flow/transport in both layers of the overburden as well as in the Jefferson

City-Cotter HSU.

The assignment of reasonable downhole flow rates to the open boreholes in the vicinity of PW-19 is
essential for creating the observed transport to the southeast in the Jefferson City-Cotter HSU and is
supportive of the CSM.

Particle tracking suggests that contaminant transport directions for layers responding to either the
locally imposed or regional flow systems can be rationalized with observed contaminant distribution
patterns. Backward particle tracking from contaminated bedrock wells (BR-08-JC, BR-09-JC, and
BR-04-JC) suggest that the Burial Pits are the source of contamination in these wells. Particle travel
times vary depending on the location of their release points within the Hematite Facility. Particles
“released” within the southwestern part of the Hematite Facility (i.e., the process buildings) tend to
have longer travel times towards their discharge point (Joachim Creek) when compared to particles
“released” within the northeastern part of the Hematite Facility (e., the Burial Pits). This is due to
the mounding in the northeastern corner of the Hematite F: acility that causes downward migration in
this area to the transmissive bedrock formations that are conductive and were assumed to have lower
porosities than the overburden.

Contaminant transport modeling of PCE and TCE in groundwater indicates that sorption and
degradation can significantly attenuate contaminant migration such that organic contamination levels
can decrease by one to two orders of magnitude within close proximity of the source areas.

Contaminant transport modeling of uranium in groundwater indicates very limited spreading of
contamination from source areas, consistent with what was observed in groundwater sample data,
The site-specific partition coefficient for uranium is two orders of magnitude higher than the sorption
coefficient for organics, resulting in significantly less migration for uranium in groundwater at the
Hematite Site when compared to PCE and TCE.



NIOSH OCAS
NIOSH Report of Dose Reconstruction under the
Energy Employees Occupational Illness Compensation
Program Act (EEOICPA)

NIOSH ID: | Social Security No. DOL District Office
Denver
— al
Energy Employee
Name:
Covered
Employment: United Nuclear Corp.
1967 - 1971 Hematite, MO
I — — —_——|
Cancer:
Calculations Performed By: . Joseph N. Dickey _ - 03/18/2008
r a — —
Peer Review Completed By: _ 03/28/2008
_ . _
Dose Reconstruction Approved By: |
4/8/2008 _|
__Peter A, Darnell, CHP, RRPT.

DRAFT Page 1 of 8

A-|o


@ retendite 1 From Cree “Nov, 24, 98

during 1975 (the values in the EIA), and is well within the 25 mrem per
year environmental dose limit for uranium fuel cycle facilities to be .
imposed by the USEPA (40 CFR 190) on December 1, 1979.

Question 4.b

6. Aceonding to your Letter of July 19, 1978, Combustion Engineering
was discharging an avenage of 35 gatlons per day of radioactive
waste water into its two evaporation ponds at that time. A year
eankier when the draft EIA was published (February 14, 1977),
apparently 100 gattons were being discharged per day into the ponds.
18 there a Limit on the number of gallons CE is allowed to discharge
per day on year to the ponds - - or may any number of gaktons be
discharged as Long as the concentration Level in each galton {in
mickacuries per milliliter of gross alpha or gross beta) is kept
within the Limits you mention? Woukd an increase in the number of
gatlons per day not cause an increase in the buildip of radioactiviéy
accumulating in the pond? 1f there is a Limit to the number of
gallons aklowed for the present plant, will this Limit be increased
when the plant's capacity is doubled as pkanned?

Answer 4.b

There is no limit to the number of gallons that may be discharged to
the evaporation ponds. An increase in gallons would result in an
increase in radioactivity in the ponds, assuming concentrations
remained unchanged.

Question 4.0 a

c. According to the formuka on page 3-13 of the EIA, it seems
that the concentration Limits of gross beta and gross alpha must
each be reduced if both beta and alpha omitters are present in the
wastes. The method mentioned is to keep the waste "quarantined in
55-gatlon drums until the contained radionuclides decay to
acceptable Levels," before discharging the wastes to the ponds.
With the hal-Lives of wraniun and thorium hasting for millenia, >.
T cannot imagine how many drums woukd be needed to stone the
Aadwaste until sufficient decay has taken place. Do you know how
many drums are at the Hematite site now, and how many mone are
planned for the expanded facility? 14 there a Limit?

Answer

The situation that you are referring to in your question has been resolved.
An elevated gross beta activity in waste solution from UF6 cylinder heel
washing was discovered in early 1976. At that time, the licensee believed
the source of the activity to be coming from Th~234 (first daughter of
U-238). It was expected ‘that this activity (hali~life of 24 days) present
in the wash solution would decay to acceptable levels in less than one
year. Therefore, the licensee planned to store approximately 5000 gallons
of this waste solution in 55 gallon drums. The first 600 gallons were
stored for six months and the expected decay did not take place. The



No site profile of the Hematite facility has been performed.
{EXHIBIT A-19} without a site profile an accurate dose reconstruction cannot be
obtained.
2.The workers were exposed to highly radioactive materials (natural and Man-made) and
toxic (including volatile organic chemicals).workers were not given proper protective
clothing and working equipment. (EXHIBITS A1-3,A-6,A-7,A-34}
A photo of deceased employee/Claimant as shown in the
issue who was working with highly
enriched uranium without any protective gear. lied
2001 of stomach cancer, his surviving spouse filed a claim in which has also been
denied. {EXHIBIT A-8, A-34}
3.The employees did not receive routine internal monitoring such as bio assays, blood
Samples, and breath test. Some did not even have urinalysis.
{EXHIBITS-A1-3,A-5,A-6 AFFIDAVITS}
4.The former Atomic Energy Commission, the Department of Energy, the Nuclear
regulatory Commission nor NIOSH has thorough personnel or environmental monitoring
Data {EXHIBIT A-9} states

“your claim that was not involved in dosimetry or dose reconstruction in the site

represented in your claim”.
5.As far as we know, NO Hematite personnel radiation dose records have been provided
To NIOSH and possibly do not exist therefore, it is quite conceivable that a fair and

accurate dose reconstruction cannot be obtained with sufficient accuracy because data is


 frevestigation to Determine the Source of "Te
. in Groundwater Monitoring Wells 17 and 17B

1.0 INTRODUCTION

Combustion Engineering (CE) operates a nuclear fuel rod manufacturing plant near Hematite,
Missouri. A topographic site figure showing the general location of the site along with
generalized topographic features is included as figure 1-1. A review of figure 1-1 shows that the
site is located between the bluffs and floodplain of Joachim Creek. General site topography dips
gently to plant south throughout the site. The ground elevation drops sharply into the existing
flood plain of Joachim Creek, approximately 400 feet plant south of the plant. Additionally the
topographic gradient drops sharply into a tributary of Joachim Creek approximately 200 feet
plant east of the plant. Joachim Creek drains into the Mississippi River near Herculaneum.

The facility currently contains a groundwater monitoring network; located predominantly along
the plant south and plant east edges of the manufacturing facility. Monitoring well WS17
formerly known as burial pit well number 4 was found to contain groundwater concentrations of
Technetium - 99 (° Tc) during previous monitoring events beginning in 1990. Previously,
(1982) increased beta activity was detected in a nearby well by an NRC contractor. WS17 may
have had a poor surface seal and was located in an area of intermittent standing surface water,
therefore it was properly abandoned and replaced with a monitoring well designated as WS17B
during June of 1996. WS17B also was found to contain concentrations of * Te; indicating the
occurrence of ° Tc was not confined to WS17.

This study was conducted to satisfy the Nuclear Regulatory Commission (NRC) who requested
additional information concerning the source of the "Tc as a condition of CE’s 1994 licence. An
initial assessment identified the evaporation ponds as a potential source of the ® Tc concentration
in WS17. However, recent groundwater contour maps developed by Gateway Environmental
Associates, Inc. (Gateway) indicate the evaporation ponds are an unlikely source for the ° Tc in
WS17 due to the direction of groundwater flow. Additionally, the direction of groundwater flow
indicates the likely source for the ” Tc in WS17 is located plant north of WS17. Plant records
indicate that areas of scrubber gravel storage, a uranium recovery area and a former ring storage
all of which are located plant north of WS17 are likely candidates for the source area.

Scrubber gravel is limestone (calcium carbonate) which is used to neutralize hydrofluoric acid
off gasses from the uranium conversion process. Currently large piles of scrubber gravel are
located plant south of the former ring storage area. The piles are outside the old fence line.

In order to determine the source of the ® Tc contained in WS17, CE contracted with Gateway. In
July, 1996, Gateway formulated a work plan to investigate the source. Based upon historical
information provided by CE and recently obtained groundwater flow data, Gateway focused the
investigation on the area of the plant located plant north of WS17, plant east of the south vault,
plant west of the storage pits and plant south of the building 256 and the loading docks. The
results of the investigation are included in this report. ‘

A) vee)

aBMo adnan Page |



Hematite
Revisited

PLANT MASCOT, “George White,”
jockeys to get in the door ahead of
Dr. Jim Carpenter. Guard Francis
Holtmeyer watches fun from inside.

DR. ED NORTH, plant manager (right), and George Brown, plant
engineer, work on a problem in North’s office in the main building.

fluoride. This gas comes from the AEC’s Oak Ridge
plant in cylinders, held firmly in intricate “bird cages.”

In the newest building is the pelleting equipment. We
walk into the proverbial beehive of activity. Engineers
and chemists are checking out the equipment, making
last-minute changes, getting ready to put the plant
onstream.

“We should be ready to go early in March,” says Dr.
Bill Tompkin, the corporation’s research and develop-
ment manager, who is overseeing startup. Here the ura-
nium dioxide will be pressed into pellets at about fifty
tons of pressure per square inch. They will be fired at
about 3000 degrees Fahrenheit into finished shapes.
These shapes may then be ground to close tolerances and
loaded into tubes. These tubes later are fabricated into
fuel elements which go into reactor cores.

“We had more experience than anyone else in using
the powder,” explains Lou Horton, “so applying this to
pelleting was a natural step. But to do it we had to leam
new t iques and develop skills entirely new to Mal-
linckrodt.”

The first pellets from this new building will go to the
Northern States reactor. At Hematite they will be placed

(L-3b

NaS
AGGLOMERATION, or “gathering together,” of UO2 powder,
starts the pelleting. Checking is Jan Ericson, chemical engineer.

in aluminum tubes, about eighteen inches long. The
tubes then will be shipped to the Universal Match Cor-
poration where they will be closed.

Horton explains, “Uranium is just another fuel—an-
other source of heat. Its big problem now is competing
with other fuels for generating electric power.”

Costs of electric power vary, of course, from area to
area—mainly because of distance from coal fields. In St.
Louis, power is relatively cheap—about four or five mills
per kilowatt hour—because southern Illinois coal fields
are close. But at places far from coal fields, the cost of
generating power may be twelve to fifteen mills. At this
rate, nuclear power is practically competitive.

This, then, is where the Hematite operation stands.
today—serving an industry which is just beginning to
realize its potential. In this service Mallinckrodt has re-
corded many firsts—beginning with the basic decision to
convert enriched uranium hexafluoride to uranium metal
and compounds for nuclear reactors. Mallinckrodt also
was first to:

... develop processes meeting requirements for safety

and criticality.



Spécial Exposure Cohort Petit U.S. Department Sf Health and Human Services
under the Energy Employees Occupation: Centers for Disease Control and Prevention
Illness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007

Special Exposure Cohort Petition — Form B
Survivor Information — Complete Section B if you are a Survivor or represer

B.1 Name of Survivor:

Mr/Mrs./Ms. First Name Middle Initial Last Name
B.2 Social Security Number of Survivor:

B.3 Address of Survivor:

Street Apt # P.O. Box

City State Zip Code
B.4 Telephone Number of Survivor: d
B.5 Email Address of Survivor:

B.6 Relationship to Employee: Q Spouse Q Son/Daughter Q Parent
Q Grandparent __@ Grandchild

Employee Information — Complete Section C UNLESS you are a labor organization.

C1 Mama nf Eemntnunns

Mr/Mrs./Ms, First Name Middle Initial Last Name
C.2 Former Name of Employee (e.g., maiden name/legal name change/other):

Mr./Mrs./Ms. First Name Middle {nitiat last Name
C.3 Social Security Number of Employee:

C.4 Address of Emplovee (if livina):

Street naam P.O. Box

City - tate Zip Code
C.5 Telephone Number of Employee:
C.6 Email Address of Employee:

C.7 Employment Information Related to Petition:
C.7a Employee Number (if known): _

C.7b Dates of Employment: Start Glo ) End 1a
C.7c Employer Name: UNITED Nuclear ¢ ORDOKAT | ow.
C.7d Work Site Location:

r la
Wespon's Employer) Hematite, Missouri

C.7e Supervisor's Name:

Name or Social Security Number of First Petitioner: _



ATTACHMENT 1- TREP Innut Tables

DRAFT Page 8 of 8

A-19


Internal Dose

Internal dose is caused by radioactive materials that are taken into the body. A chronic intake is
an intake of radioactive material that occurs over an extended period of time (typically weeks or
longer). An acute intake is an intake of radioactive material that occurs over a short period of
time (typically minutes to hours). Regardless of the rate at which the intake occurs, the internal
radiation dose received from radioactive materials having long half-lives occurs over an
extended period of time, and is therefore, considered chronic.

A dosimetry summary corresponding tc employment at United Nuclear
Corporation indicated he participated in the bioassay sampling program with an average urine
sample activity of 9 dpm/L. The assumption was made th wovided routine urine
samples on a quarterly basis throughout his employment during the AEC contract. This data was
applied to a computer code, the Integrated Modules for Bioassay Analysis (IMBA),’ to
determine annual internal intake values that were then used to develop annual organ doses based
on those intakes over the intake period. In addition to this calculated value, the residual airborne
contamination intake values were also applied to the internal dose reconstruction from the
technical basis document.’ As a claimant-favorable assumption, uranium-234 was assigned for
all of the internal uranium activity, Application of solubility class $ produced the most claimant-
favorable exposure to the urinary bladder and; therefore, was used for this dose reconstruction.
The ICRP 66 lung model with default aerosol characteristics in conjunction with ICRP 68
metabolic models were applied to the JMBA internal dose calculations.

The total internal dose assignec ‘inary bladder was 0.049 rem.

Dose from Radiological Incidents

The computer assisted telephone interview was reviewed carefully by the dose reconstructor.
expressed concern of Technetium 99 in the ground water at and around the facility.
Technetium 99 (Te-0TM i + seee-te4 e-anium product. External radiation due to Tc-99 would
have been captured ¢ external dosimetry or on the external dosimetry from
which the external exposure values in the technical basis document were developed. Internal
exposures due to Tc-99 are accounted for by the internal intake assignment of uranium-234
rather than the actual uranium isotopic composition worked with at United Nuclear Corporation.

No additional information affecting the dose reconstruction was identified.

Uncertainty
Dose values were input into IREP'® using distribution parameters specified in the site technical

basis document.”

Summary

was assumed to have been exposed to various sources of ionizing
rawauun Uusig Ho vunpsoyment at the United Nuclear Corporation facility. The estimated dose
to rinary bladder was |.120 vem through reconstruction under the EEOICPA.
Attachment | contains the dose reconstruction summary sheets that will be used by the
Department of Labor to make the final probability of causation determination for the claim.

DRAFT Page 6 of 8

ns


'

497-20-6694 @ @ : a
GLENN E, FRANKENBACH 7 7 /
Seo Chamizals Dinas (S07 | pe |
pe i
|

626°N. MILL ST.
FESTUS, MO. oe
llinckvou, "> :

Mallinckrodt Chemical Works: ” U.S, POSTAGE

i
!
|
BULK RATE {
Malilackrodt Chamnical Works hoy : - i
‘Setond and Maltinckeadt Streets Second & Mallinckrodt Streets, St.iLouis 7, Mo, + 72 Gold Street, New York 8, N. Y. PAID |
St. Louls 7, Missourt CHICAGO © CINCINNATE + CLEVELAND » DETROIT + LOS ANGELES * PHILADELPHIA « SAN FRI CISCO. PERMIT No: 186. Hl
a : 2 ST.LOUIS, MO.

aa |

i

f

Roum Portage Guaranteed IN CANADA: MALLINCKRODT CHEMICAL WORKS LIMITED » MONTREAL + nyo 7

Tomorrow's jobs. ai

are being decided by today’s profits

lars inthe ©

‘ALLINGKRODI has invested two million d ||
| the commercial . | I-
? | r

Hematite plant for supplying fuel] to
nuclear power industry..(See page 2) : | :
To do this'there lid to be—profits after taxe; . .

That modern plant has provided sixty new jobs. And the (
materials to keep it-fed Drovide more jobs outside. of hod te
Mallinckrodt. No new plant—no new jobs} np profits > io
saved—no new plant. It’s just as simple i :

and just as serious as that. | 7
For “Hematite plant” substitute “machine shop,” “laboratory” | |

or any other aggregation of buildings and sae

in which you are interested, The samé -!

Principle applies — growth, expansion, jobs
ram profits saved and invested. |

n come only,



Special Exposure Cohort Petitiol U.S. Deparment Micah and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Illness Compensation Act National Institute for Occupational Safety and Health

ws OMB Number: 0920-0639 Expires: 05/31/2007
Special Exposure Cohort Petition — Form B Appendix — Continuation Page

Continuation Page — Photocopy and complete as necessary.

2) Neve lay Quay 22-
Os aN Qo thorized (Ce pve senitak ve
as [7

_ ; (epresedt the Class

—OK _Smployeces of the Nemok fe Site

lo= la- OF

Sy

Name or Social Security Number of First Petitioner:



eo ae

Investigation to Determine the Source of
Technetium-99 ;
in Groundwater Monitoring Wells 17 and 17B

Prepared for

Combustion Engineering
Hematite, Missouri

Prepared by

Gateway Environmental Associates, Inc:

September 1996

Copyright®, Gateway

Environmental Associates, Inc.

2085 Cralgshire Drive, St. Louis, Missouri 63146, 314/205-8053, FAX: 314/434-7071

1996 1)

SON
Sor malty

Seemann

ptA


pep O12) TS

ou-F | NUCLEAR FUELS COMPANY

a A DIVISION OF GULF OIL CORPORATION

GRASSLANOS ROAD
ELMSFORD, NEW YORK 10523
914.882.9000

Hematite, Missouri 6304

eply refer to

NIS:DGD-74-23 : ’ February 6, 1974

Missouri Clean Water Commission
Post Office Box 154
Jefferson City, Missouri 65101

Aten: Mr, James P, Odendahl
Dear Mr. Odendahl:

Pursuant to our telephone conversation of December 21, 1973, enclosed
find an executed application for renewal of the operating permit for
our septic system and a check for the permit fee,

As you were advised, Gulf Oil Corporation is divesting itself of Gulf
Nuclear Fuels Company (formerly Gulf United Nuclear Fuels Corporation),
a wholly owned subsidiary. This will result in. shutdown of the Hematite,
Missouri, plant in April 1974 and subsequent decommissioning, which is
expected to be complete about late 1974,

We will inform you when these operations are completed, and respectfully
request that the permit fee be pro-rated and the unused portion refunded,

Additionally, I am returning, uncompleted, the application form for a
permit to discharge process liquids into surface waters that was requested
by letter from the Clean Water Commission dated November 29, 1973, Term-
ination of our operations will negate the need for this permit.

For your information, I am also enclosing copies of correspondence with
EPA on this subject, You may wish to retain this for your file, I
believe the above information conforms to your suggested response. Should
you have questions, please contact me.

Very truly yours,

Mawel 4 Meer

David G. Darr
Senior Nuclear and Industrial
Safety Representative

DGD/j£

ec: Mr. P. Loysen, Elmsford

A. 32


Special Exposure Cohort ron U.S. Sepanmon ican and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Iliness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Petitioner Authorization Form Page 2 of 2

Public Burden Statement

Public reporting burden for this collection of information is estimated to average 3 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Use of this form is voluntary. Failure to use this form will not result in the denial of any right, benefit, or
privilege to which you may be entitled.

Name or Social Security Number of First Petitioner:



Spevial Exposure Cohort Th U.S. Sopartmen Whoann and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
Illness Compensation Act Nationa! Institute for Occupational Safety’and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Page 1 of 7

Cohort Petitio
—

sie
General Instructions on Completing this Form (complete instructions are available in a separate packet):
Except for signatures, please PRINT all information clearly and neatly on the form.

Please read each of Parts A — G in this form and complete the parts appropriate to you. If there is more
than one petitioner, then each petitioner should complete those sections of parts A ~ C of the form that apply
to them. Additional copies of the first two pages of this form are provided at the end of the form for this pur-
pose. A maximum of three petitioners is allowed.

If you need more space to provide additional information, use the continuation page provided at the end of
the form and attach the completed continuation page(s) to Form B.

If you have questions about the use of this form, please call the following NIOSH toll-free phone number and
request to speak to someone in the Office of Compensation Analysis and Support about an SEC petition:
1-800-356-4674,

QA Labor Organization, Start atD on Page 3

ityou Q An Energy Employee (current or former), StartatC on Page 2
are: OA Survivor (of a former Energy Employee), StartatB on Page 2
A Representative (of a current or former Energy Employee), StartatA on Page 1

Representative Information — Complete Section A if you are authorized by an Employee or
Survivor(s) to petition on behalf of a class.

Are you a contact person for an organization? Q Yes (Go to A.2) {No (Go to A.3)

A.2_ Organization Information:

Name of Organization

Position of Contact Person

A3 Nama af Datitinn Ranracantative:

Mrvirs.MIS. FirstName Middle Inttal Last Name
A4_ Address:

Stree+ oven P.O. Box
City State 7in Code

A.5 Telephone Number:

A. Email Address:

AZ xX Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization

Name or Social Security Number of First Petitioner: _



AFFIDAVIT

| im the survivin who was an employee of
United Nuclear and had worked at the Hematite Site from 1957-2000 as a

worked with highly enriched uranium as part of the special projects that were
performed there as part of government contracts as well as commercial.

worked at this facility for many years without proper protective gear (gloves,
respirators, etc.) as you may see in the company’s F
photo working bare handed, that was taken of him.

died of stomach cancer 2001
As a surviving spouse, ! had filed a claim with the EEOICA May 5, 2003,
As of this day, June 6, 2008 my claim has not been paid.

meets all requirements as part of this compensation program having worked 250 days, in
the covered time frame, and has a diagnosis of a covered cancer.

| myself also have been diagnosed with multiple myeloma which may have been caused
secondary exposure,

NOTARY:

State of MISSOURI

County of JEFFERSON

Subscribed and sworn to before me this 13 day of June in the year 2008.

Pibotee K Marte ” DEGORAH K. GUENTHER

Notary Public - Notary Seal
Deborah K Guenther STATE OF MISSOURI
Jefferson County
i ‘xpires: 6-29-08



@ @ BIR

Vof. 1

Tan-206°7

1. INTRODUCTION

This Report presents the results of the remedial investigation (RI) conducted at a former fuel cycle
facility that is located within 228 acres of property in Hematite, Missouri, and is currently owned by the
Westinghouse Electric Company, LLC (WEC). WEC ceased facility operations in June 2001 and is
proceeding, with Site characterization, remediation, and facility decommissioning. This Report was
prepared by Science Applications International Corporation (SAIC) under contract to WEC.

As used throughout this document, the “Hematite Facility” refers to the central portion of the property,
encompassing the historic primary operations area, Site Pond and burial pits, while the “Hematite Site”
refers to the “Hematite Facility,” and other areas that were the focus of this investigation based on potential
impacts by previous Facility operations. “Property” refers to the 228 acres of land owned by Westinghouse.

1.1. GOALS AND OBJECTIVES OF THE REMEDIAL INVESTIGATION

The overall goals of the RI are to characterize the nature and extent of contamination resulting from
previous operations at the Hematite Facility and to reasonably predict contaminant fate and transport
(F&T) in the surface and subsurface environment. Characterization data collected during the RI are being
used in risk assessment studies that will quantify the impact of contamination associated with previous
operations on human health and the ecological environment. The results of the RI will also be used in
subsequent feasibility studies (FSs) to determine suitable remedial alternatives for the Hematite Site.

To achieve the goals of the RI, characterization and modeling activities were designed with the
following specific objectives:

¢ — To establish a conceptual model for hydrogeologic conditions at the Hematite Site that will be used
as a framework for assessing contaminant migration pathways.

* — To obtain information necessary for developing a conceptual site model (CSM), including lithologic
characteristics and hydraulic conductivities for the overburden and bedrock formations,
potentiometric surfaces in the overburden and bedrock groundwater, hydraulic gradients between
hydrogeologic units, and interactions between groundwater and surface water features at the
Hematite Site.

« To determine whether historic operations have impacted surface water and sediment, and whether
contaminants are migrating off-Site through surface water and sediment migration pathways.

* To assess the impact of historic operations on surface and subsurface soils, including the
identification of potential sources for groundwater and surface water contamination.

¢ To define the sources of contamination and characteristics of these source areas that are important to
the evaluation of remedial alternatives.

* To assess the nature and extent of contamination in the shallow (i.e., overburden) groundwater, and
lo determine potential contaminant migration pathways from possible source areas within the
Hematite Facility to surface water and deeper (i.e., bedrock) groundwater.

* To assess the nature and determine the horizontal and vertical extent of contamination in bedrock
formations where contaminants have been detected during previous investigations.

I-1

het


security without proper protective clothing, handling of doors, knobs, etc. and also
handled exposed employee monitoring badges that were turned in by employees at the
end of each shift on a daily basis. pulmonary fibrosis diagnosis is consistent

With exposure to beryllium, he also having every symptom except one.

The Missouri Department of Health and Human services learned about off site
groundwater contamination as early as December 2000 but the current owner
Westinghouse did not notify the residents of off site contamination had migrated beyond
the plant site until March of 2001.

The fact that there was off site contamination is evidence of a severe lack of quality
controls. There has been a lack of disclosure of information to the public, workers, and

subcontractors by the NRC, licensee, and its contractors..

During the cold war everything seemed justified and if you were against it you were
labeled “unpatriotic”. The cold war basic motto was “war is hell” and in order to protect
National Security a lot of people must die and get hurt.

The workers as I have been told, were unaware of the toxicity and lethal
activities/operations they so blindly performed under the Atomic Energy Commission.
The federal government knew the effects of radiation since the early 1940s.
Although the workers drew a salary while working on the Atomic Energy contract, you
can bet if they were told they may become terminally ill or even die, they would have
thought twice about working there... They were their own “Manchurian candidate”.

With the absence of records, safety equipment, and proper monitoring of their work


APPENDIX
SPECIAL EXPOSURE COHORT FORM B FOR HEMATITE SITE

PETITONER AUTHORIZATION FORM

PETITIONERS COHORT ADDENDUM 1-13

A. 1-4 AFFIDAVIT EMPLOYEE
A.5 AFFIDAVIT . EMPLOYEE
A.6 AFFIDAVIT” EMPLOYEE
A.7 AFFIDAVIT SURVIVOR
A.8 AFFIDAVIT “SURVIVOR
A9-17 DOSE RECON REPORT-DHHS
A.18-20 ] DOSE RECON ACTIVITY REPORT

A.21-22 ENGINEERING EVALUATION COST ANAYLIS WESTINGHOUSE
A.23-30 LETTER
A.31-32 GULF NUCLEAR CORRESPONDENCE
A.33-38 MALLINCKRODT CHEMICAL WORKS NEWS ARTICLE
A.39-61 REMEDIAL INVESTIGATION REPORT HEMATITE SITE JANUARY
2007

A.62-65 FEDERAL REGISTER/VOL.66, NO.11 JANUARY 17,2001 NOTICES


Federal Register/Vol. 66, No. 11/ Wednesday, January 17, 2001/Notices 4005

system. The list indicates private firms drawn from a variety of historical comments or additional information
that processed, produced, or provided documents, and much data remains about its beryllium vendors.
beryllium metal for the Department, as —_ incomplete. The Department welcomes a
defined by the Act. This information is Covered Facility List <<.
Jurisdiction Facility name Location Facility type
Southern Research Institute .... Sylacauga ..
Speed Ring Experimental & Tool Company Culman ..
Tennessee Valley Authority Muscle Shoals ... AWE
Amchitka island Nuclear Explosion Site Amchitka Island DOE
Project Chariot Site Cape Thompson DOE
Arthur D. Little Co. San Francisco AWE
Atomics International .. Canoga Park BE
Burris Park Field Stati Kingsburg AWE
Ceradyne, Inc. Santa Ana BE
Dow Chemical Co. Walnut Creek AWE
Electro Circuits, Inc. Pasadena ... AWE
Energy Technology Engineering Center Santa Susana DOE
General Atomics ..... La Jolla ... AWE/BE/DOE
General Electric Vallecitos Pleasanton .. AWE
Hunter Douglas Aluminum Corp. Riverside AWE
Laboratory for Energy-Related Health DOE
Laboratory of Biomedical and Environmental Sciences | Los Angeles DOE
Laboratory of Radiobiology and Environmental Health {| San Francisco DOE
Lawrence Berkeley National Laboratory Berkeley .. DOE
Lawrence Livermore National Laboratory Livermore DOE
Sandia Laboratory, Salton Sea Base Imperial County DOE
Sandia National Laboratories—Livermore .. Livermore DOE
Stanford Linear Accelerator Center Paio Alto .. DOE
Stauffer Metals, Inc. Richmond ...
University of California Berkeley AWE/DOE
Coors Porcelain .. Golden BE
Project Rio Blanco Nuclear Explosion Site Rifle . DOE
Project Rulison Nuclear Explosion Site . Grand Valley DOE
Rocky Flats Plant Golden DOE
Shattuck Chemical .. Denver AWE
University of Denver Research Institute .. Denver AWE/BE
American Chain and Cable Co. Bridgeport AWE
Anaconda Co. Waterbury AWE
Bridgeport Bras: Bridgeport AWE
Combustion Engineering .. . | Windsor AWE/DOE {
Connecticut Aircraft Nuclear Engine Lab. (CANEL) ..... | Middletown... BE/DOE
Dorr Corp. . Stamford . AWE
Fenn Machinery Co. Hartford AWE
New England Lime Co. .. Canaan AWE
Seymour Specialty Wire .. Seymour AWE/DOE
Sperry Products, Inc. Danbury AWE
Torrington Co. Torrington AWE
Allied Chemical y North Claymont AWE
National Bureau of Standards, Van Ness Street Washington AWE
Naval Research Laboratory Washington AWE/DOE
American Beryllium Co. Sarasota BE
Armour Fertilizer Works Bartow . AWE
C.F. Industries, Inc. Bartow .. AWE
Gardinier, Inc. Tampa AWE
International Minerals and Chemical Corp Mulberry AWE
Pinellas Plant Clearwater DOE
University of Flo Gainesville AWE
Virginia-Carotina Chemicat Corp Nichols .. AWE
W.R. Grace Co., Agricultural Chemical Div Ridgewood AWE
Argonne National Laboratory—West Scoville . DOE
Idaho National Engineering Laboratory Scoville .. DOE
Allied Chemical Corp. .. Metropolis AWE
American Machine and Metals, Inc. E. Moline .. AWE
Argonne National Laboratory-East Argonne DOE
Armour Research Foundation Chicago AWE
Blockson Chemical Co Joliet .. AWE
C-B Tool Products Co. Chicago AWE
Crane Co. ... Chicago AWE
ERA Tool and Engineering Co. Chicago AWE
Fansteel Metallurgical Corp. North Chicago .. BE
Fermi National Accelerator Laboratory .. Batavia
Granite City Stee! Granite
Great Lakes Carbon Chicago
GSA 39th Street Warehouse Chicago
ete

fh-Wpd



MIOSH Dose Reconstruction Activity Report @ r Page 3 of 3
Medical Information

The table below provides information on the energy employee's cancers that were verified by DOL.

IT
| Cancer Description Diagnosis Date

Papillary Transitional Cell Carcinoma of the Urinary Bladder (both posterior & left lateral wal 2003

DOL is responsible for verifying covered employment and medical information for your case. If you have any
questions regarding the employment or medical information stated above, please contact either your case examiner with
DOL or the District Office where you filed your case.

Cleveland, Ohio 1-888-859-7211 Jacksonville, Florida 1-877-336-4272
Denver, Colorado 1-888-805-3389 Seattle, Washington 1-888-805-3401

NIOSH Tracking Number: 016152

f-20


ae

BIA.296-5640

May 23, 1972

In Reply Refer to
NLS: DGD- 72-55

Jn accord with the provisions of the Atomic Energy Commission Regulations
entitled "Standards for Protection Against Radiation" (10 CFR Part 20),
this letter will inform you of your exposure to radiation and radioactive
material while employed by or assigned to Gulf United Nuclear Fuels
Corporation (formerly United Nuclear Corporation), Hematite, Missouri.
facility licensed under AKC License SNM~33. You should preserve this
report for future reference.

Name (of record):

Social Security Number:

Period of kmployment
or Assignment:

Exposure to External Radiation

Period of Exposure © Whole Body Exposure Exposure, Skin of Whole Body

7 TA . 0,330 Rem, 0.330 Rem,

Internal Exposure to Radiation

Urinary bio-assay has been used to measure internal exposure to radiation.
Your average urinary bio-assay level for the above listed period of exposure
was 9 dpm/litex., This may be compared to the plant action level of
100 dpm/liter. No standards for interpretation of bio-assay levels have
been adopted by radiation protection authorities,

Other methods for assessing internal exposure may have been used, In this
case, the results _and estimate_of exposure may be found in Attachment I.

Attachment I is » is not | * j attached.

Very truly yours,

ff >
excl yy haat’
David G, Darr
Health Physics Specialist ~

BeD/ if

A-4 00 °


decision. Final determinations are made by the Department of Labor based on standards
determined by EEOICPA and its implementing regulations.

Dose Reconstruction Overview

The Office of Compensation Analysis and Support has performed a dose reconstruction for
in accordance with the applicable requirements of the Energy Employees
Occupational Illness Compensation Program Act (EEOICPA). Information provided by the

Department of Labor (DOL) indicates that vorked as chemical quality control
technician at United Nuclear Corporation fro 1967 throug] 1971 and
was diagnosed with urinary bladder cancer on 2003. Per the requirements of 42 C.F.R.

§ 82, 10()),! only the dose incurred up to the point of cancer diagnosis was included in this
assessment.

From 1958 to 1969, the United Nuclear Corporation processed uranium scrap for the AEC,
recovering enriched uranium from it for use in the nuclear weapons complex. Residual
radioactivity was assumed to remain at the site until 2006. dose reconstructed
under the EEOICPA was 1.120 rem to the urinary bladder. The dose was calculated only for the
urinary bladder because of the specific type of cancer associated with this claim.

occupational radiation dose was reconstructed based on current science,
documented experience, and relevant data. Under these assumptions, NIOSH has determined
that further research and analysis will not produce a level of radiation, dose resulting in a
probability of causation of 50% or greater. Per 42 C.F.R. § 82. 10(k),' NIOSH has determined
that sufficient research and analysis have been conducted to consider this dose reconstruction
complete.

If the facts surrounding this dose reconstruction change (e.g.. the date of diagnosis is moditied or

an additional covered cancer is diagnosed), the measures used to reconstruct the dose may not be
applicable.

Information Used

Specific parameters were applied to-available site records in order to assign organ dose based on
information in the NIOSH External Dose Reconstruction Implementation Guideline,’ the NIOSH
Internal Dose Reconstruction Implementation Guideline,’ and NIOSH Radiation Exposures
Covered for Dose Reconstructions under Part B of the Energy Employees Occupational llness
Compensation Program Act Implementation Guideline.” The modeled organs were selected
based on information in the Technical Information Bulletin: Internal Dosimetry Organ. External
Dosimetry Organ, and IREP Model Selection by 1(CD-9 Code® The primary sources of
information used for this dose reconstruction were dosimetry summary from his
employment at United Nuclear Corporation and the 1 eenmea: basis Document: Site Profiles for
Atomic Weapons Employers that Refined Uranium and Thorium, Appendix D, United Nuclear
Corp.,’ prepared for the EEOICPA project.

DRAFT Page 4 of 8

i-


Federal Register/Vol. 66, No. 11/Wednesday, January

17, 2001 / Notices 4003

announces a change to a closed session
meeting.

DATES: The meeting will be held at
0900, Wednesday, February 14, 2001.

ADDRESSES: The meeting will be held at
Palisades Institute for Research
Services, 1745 Jefferson Davis Highway,
Suite 500, Arlington, VA 22202.

FOR FURTHER INFORMATION CONTACT:
Elise Rabin, AGED Secretariat, 1745
Jefferson Davis Highway, Crystal Square
Four, Suite 500, Arlington, Virginia
22202.

SUPPLEMENTARY INFORMATION: The
mission of the Advisory Group is to.
provide advice to the Under Secretary of
Defense for Acquisition and
‘Technology, to the Director Defense
Research and Engineering (DDR&E), and
through the DDR&&, to the Director
Nefense Advanced Research Projects
Agency and the Military Departments in
planning and managing an effective
research and development program in
the field of electron devices.

The Working Group B meeting will be
limited to review of research and
development programs which the
military proposes to initiate with \
industry, universities or in their
laboratories. The microelectronics area
includes such programs on
semiconductor materials, integrated
circuits, charge couple devices and
memories. The review will include
classified program details throughout.

In accordance with section 10(d) of
Pub. L. No, 92-463, as amended, (5
U.S.C. App. 10(d) (1994)}, it hes been
determined that this Advisory Group
meeting concerns matters listed in 5
552b(o)(1) (1994), and that
accordingly, this meeting will be closed
to the public,

Dated: January 10, 2001.

1.M, Bynum,

Alternate OSD Federal Register Liaison
Officer, Department of Defense.

{FR Doc. 01-1273 Filed 1-16~01; 8:45 am]
BILLING CODE 5001—10-

DEPARTMENT OF DEFENSE
Office of the Secretary of Defense

Department of Defense Wage
Committee; Notice of Closed Meetings

Pursuant to the provisions of section
10 of Public Law 92-463, the Federal
Advisory Committee Act, notice is
hereby given that closed meetings of the
Department of Defense Wage Committee
will be held on February 6, 2001;
February 13, 2001; February 20, 2001;
and February 27, 2001, at 10:00 a.m, in

Room A105, The Nash Building, 1400
Key Boulevard, Rosslyn Virginia.
Under the provisions of section 10(d)
of Public Law 92-463, the Department
of Defense has determined that the
meetings meet the criteria to close
mectings to the public because the
matters to be considered are related to
internal rules and practices of the
Department of Defense and the detailed
wage data to be considered were
obtained from officials of private
establishments with a guarantee that the
data will be held in confidence.
However, members of the public who
may wish to do so are invited to submit
material in writing to the chairman
concerning matters believed to be
deserving of the Committee’s attention.
Additional information concerning
the meetings may be obtained by writing
to the Chairman, Department of Defense
Wage Committee, 4000 Defense
Pentagon, Washington, DC 20301-4000.
Dated: January 10, 2001.
LM. Bynum,
Alternate OSD Federal Register Liaison
Officer, Department of Defense.
[PR Doe. 01-1269 Filed 1-16-01; 8:45 am}
BILLING CODE S001-10-M

DEPARTMENT OF ENERGY

Energy Employees Occupational
lllness Compensation Act of 2000; List
of Covered Facilities

AGENCY: Department of Energy.
ACTION: Notice of listing of covered
facilities.

SUMMARY: The Energy Employees
Occupational Iiiness Compensation Act
of 2000 (“Act”), Public Law 106-398,
establishes a program to provide
compensation to individuals who
developed illnesses as a result of their
employment in nuclear weapons
production-related activities and at
certain federally-owned facilities in
which radioactive materials were used.
On December 7, 2000, the President
issued Executive Order 13179 (“Order”)
directing the Department of Energy
(“Department’” or “DOE") to list covered
facilities in the Federal Register. This
notice responds to both the Act and the
Order.

FOR FURTHER INFORMATION CONTACT:
Office of Worker Advocacy, 1-877-447—
9756,

ADDRESSES: The Department welcomes
comments on this list. Individuals who
wish to suggest additional facilities for
inclusion on the list, indicate why one
or more facilities should be removed
from the list, or provide other

A-G2

information may contact: Office of
Worker Advocacy (EH-8), U.S.
Department of Energy, 1000
Independence Avenue, SW.,
Washington, DC 20585, email:
worker_advocacy@eh.doe.gov, toll-free:
1-877-447-9756.

SUPPLEMENTARY INFORMATION:

Purpose: The Energy Employees
Occupational [liness Compensation Act
of 2000 (“Act”), Public Law 106-398,
establishes a program to provide
compensation to individuals who
developed illnesses as a result of their
employment in nuclear weapons
production-related activities and at
certain federally-owned facilities in
which radioactive materials were used.
Gn December 7, 2000, the President
issued Executive Order 13179 (“Order”}
directing the Department of Energy
(“Department” or “DGE”) to list covered.
facilities in the Federal Register.
Section 2. c. vii of the Order instructs
the Department to list three types of
facilities:

(1) Atomic weapons employer
facilities, as defined in section 3621 (4)
of the Act;

(2) Department of Energy facilities, as
defined by section 3621 (12) of the Act;
and

(3) Beryllium vendors, as defined by
section 3621 (6) of the Act.

Compensation options and
mechanisms are defined differently for
each of these facility categories. The
atomic weapons employer category
includes facilities in which the primary
work was not related to atomic
weapons, and consequently these
facilities are not commonly known as
atomic weapons facilities. Their
inclusion in this list is consistent with
the Act, and is not intended as a
classification for any other purpose.

The list at the end of this notice
represents the Department’s best efforts
to date to compile a list of facilities in
these three categories. Reconstructing
the operational history of the nuclear
weapons system over a sixty-year period
is a complex and sometimes imprecise
undertaking. Some list entries are based
on records that contain the names and
addresses of companies and facilities at
the time work was performed for the
Department and its predecessor federal
agencies. The list may identify a
corporate headquarters facility as a
production location, or may contain
some inadvertent duplication because of
changes in names, ownership, and
addresses, Similarly, attempts to
minimize duplication may have resulted
in the inadvertent omission of
subsidiaries and satellite locations that
should be included. Accordingly, the


lacking for this site. NIOSH had informed that the only dosimetry and whole
body counts were the record aad furnished himself. {EXHIBIT A-3 #8

iffidavit, EXHIBIT A-19 UNITED NUCLEAR CORP’S
“NO” RESPONSE AS STATED ON DOSE ACTIVITY REPORT
JANUARY 2007, EXHIBIT A-9 LETTER FROM DEPT. OF HEALTH AND
HUMAN SERV. TC MARCH 27,2008}
6..Because the Hematite site was so contaminated as early as 1956, In a letter dated
1973 the Hematite site was to be decommissioned {EXHIBITS A31-32 GULF
UNITED DECEMBER 27 LETTER DATED 1973, FEBRUARY 6, 1974}
and dismantled but instead remained active as a commercial manufacturer until 2000
without a proper decommissioning. Residual contamination is evidently present and just
as radioactive today.

7. Employees- both salary and hourly, union and nonunion, during the time frame of
1958 to the present, should be included in the special exposure cohort due to the residual
contamination that presently remains at this site as of 2006 and beyond. {EXHIBITA-13
8.A report sent from Westinghouse dated 11-14-2006 including an “alleged” bioassay of

dated January 1967-Dec. 1971 could in fact be a falsified document as
claims he never participated in giving a urine sample with the exception of
initial hiring. {EXHIBIT A-3 #8 AFFIDAVIT}

9. “Beryllium metal has been an important material for atomic weapons production,
and it was used at many places throughout the production system”. Federal register Vol.

66, No. 11/Wednesday, January 17, 2001/Notices, {EXHIBIT A63-64}

1D


<

4004

Federal Register/Vol. 66, No. 11/Wednesday, January

17, 2001 / Notices

Department is continuing its research
efforts in order to better understand past
production activities, and DOE intends
to update this list at least once annually
so long as new information becomes
available. The public is invited to
comment on the list and to provide
additional information.

In addition to continuing its research
efforts, the Department is developing
information dissemination mechanisms
to make facility-specific data available
to the public, including a publicly
accessible database of site-related
information. This database will help
ensure that the Department keeps track
of facilities involved in atomic weapons
and other work potentially resulting in.
contamination or exposure. The site
database will include, among other
information, the type of nuclear
weapons-related production work done,
the dates such work occurred, and
available health and safety data
concerning the facility. The listing of
facility name and location in this notice
represents only a first step in providing
information to the public.

The Act does not cover workers
involved in uranium mining and
milling, or those who worked in support
of naval nuclear propulsion programs.
Consequently, facilities associated with
this type of work are not listed in this
notice, Some workers who became ill as
aresult of their employment at these
facilities may be covered by other
programs such as the Radiation
Exposure Compensation Act (RECA),
the Federal Exposure Compensation Act
(FECA), or other jurisdictions’ worker
compensation programs.

Introduction to the Covered Facility
List

The list that follows covers the three
categories of employers defined by the
Act: atomic weapons employers
(“AWE")}, Department of Energy
facilities (“DOE”), and beryllium
vendors (“BE”). Some facilities fall into
more than one category. For example, if
a private contractor facility handled
both radioactive materials and
beryllium, it will have “AWE” and
“BE” in the “facility type” column. For
another example, a facility will have
both “DOE” and “AWE” codes if
ownership changed between the DOE
and another entity. The Department
intends to provide facility-specific
explanations of the applicability of
these categories through the database
mentioned above.

Each of the categories is defined
below:

1, Atomic Weapons Employers

Section 3621 (4) of the Act defines an
atomic weapons employer as “an entity
that—

{A) processed or produced, for the use
by the United States, material that
emitted radiation and was used in the
production of an atomic weapon,
excluding uranium mining and milling;
and

{B) is designated as an atomic
weapons employer for purposes of this
title by the Secretary of Energy.”

Most facilities listed as an AWE
conducted nuclear weapons-related
work for a limited period of time or in
certain select areas of the plant. For
example, some sites worked with
radioactive materials to evaluate
processing machinery that was being
considered for use in atomic weapons
production, Radioactive materials may
not have been used as a routine part of
the facility’s operations. The Act covers
those workers who became sick as a
consequence of their work in support of
nuclear weapons production activities,
and was not intended to cover all
workers at each site named.

The lines between research, atomic
weapons production, and non-weapons
production are often difficult to draw.
For the purposes of this notice, and as
directed by the Act, only those facilities
whose work involved radioactive
material that was connected to the
weapons production chain are included.
Available information about many of
these facilities is incomplete or unclear,
and the Department welcomes
comments or additional information
regarding facilities that may have
supported atomic weapons production
that are not on this list, as well as
information that clarifies the work done
at facilities named below.

2, Department of Energy Facilities

Section 3621 (12) of the Act defines
a DOF facility as “any building,
structure, or premise, including the
grounds upon which such building,
structure, or premise is located—-

(A) in which operations are, or have
been, conducted by, or on behalf of, the
Department of Energy (except for
buildings, structures, promises, grounds,
or operations covered by Executive
Order 12344, pertaining to the Naval
Nuclear Propulsion Program); and

(B) with regard to which the
Department of Energy has or had—

(i) A proprietary interest; or

(ii) Entered into a contract with an
entity to provide management and
operation, management and integration,
environmental remediation services,
construction, or maintenance services.”

R~W3

Consistent with this definition, the
Department has taken a broad view of
where operations have been conducted
by DOE or its predecessor agencies. The
list includes any facility handling
radioactive materials or beryllium in
which the Department had management
and operations, management and
integration, environmental remediation,
or construction and maintenance
contracts, This broad definition
includes many facilities which are not
generally thought of as Departmental
facilities, as well as facilities which are
not necessarily involved with weapons-
related work. For example, some
universities and private companies are
included because the Department
contracted for environmental
remediation services at these sites, even
though the Department did not own the
facility. Also, some DOE-owned
laboratories are included because they
do work involving radioactive materials,
even though that work is not related to
nuclear weapons production.

The Act covers production workers at
the gaseous diffusion plants at Paducah,
KY and Piketon, OH. Production
workers at these facilities are covered
for work conducted until July 28, 1998,
when the facilities were privatized
under the control of the United States
Enrichment Corporation (USEC, Inc.)

The listing of Department of Energy
facilities is only intended for the context
of implementing this Act and does not
create or imply any new Departmental
obligations or ownership at any of the
facilities named on this list.

3. Beryllium Vendors

Section 3621(6) of the Act defines
beryllium vendor as the following:

“(A) Atomics International.

(B) Brush Wellman, Incorporated, and
its predecessor, Brush Beryllium
Company.

(C) General Atomics.

(D) General Electric Company.

(E) NGK Metals Corporation and its
predecessors, Kawecki-Berylco, Cabot
Corporation, BerylCo, and Beryllium
Corporation of America.

(F) Nuclear Materials and Equipment
Corporation.

(G) StarMet Corporation, and its
predecessor, Nuclear Metals,
Incorporated.

(H) Wyman Gordan, Incorporated.

() Any other vendor, processor, or
producer of beryllium or related
products designated as a beryllium.
vendor for purposes of this title under
Section 3622.”

Beryllium metal has been an
important material for atomic weapons
production, and it was used at many
places throughout the production


Spécial Exposure Cohort ra U.S. Soparimen MM reat and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
Iliness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Appendix — Petitioner 3

Use this Appendix for Petitioner 3.

This appendix form is to be used as needed. Petitioner 3, or his or her representative, should complete the
parts applicable to him or her.

Refer to the General Instructions on completing petitioner information for Parts A, B, or C.

If you need more space to provide additional information, use the continuation page provided at the end of
the form and attach the completed continuation page(s) to Form B.

Except for signatures, please PRINT all information clearly and neatly on the form.

Q An Energy Employee (current or former), Start at C

If you are: |) A Survivor (of a former Energy Employee), Start at B

QA Representative (of a current or former Energy Employee), Start at A

Representative Information — Complete Section A if you are authorized by an Employee or
Survivor(s) to petition on behalf of a class.

Are you a contact person for an organization? O Yes (Go to A.2) No (Go to A.3)

A.2 Organization Information:

Name of Organization

Position of Contact Person

A.3. Nama af Patitinn Ranracantativa:
WIMFs/MIS.  rirst Name Wwiaale initiat Last Name

A4 Address:
Street ante P.O. Box
City Sint 7m Onde

A.5 Telephone Numbe
A6 Email Address:

A.7 Check the box at left to indicate you have attached to the back of this form written authorization to
petition by the survivor(s) or employee(s) indicated in Parts B or C of this form. An authorization
form for this purpose is provided.

Name or Social Security Number of First Petitioner:



NEW PRODUCT, uranium pellets, is in-

spected by technician Glenn Frankenbach. 4

A NEW SIGN with the operation’s new name
illustrates the changes at our Hematite plant.

HEMATITE
REVISITED

Mose Raymond Hauser was amazed. Three years
ago, MCW’s Lou Horton was telling him, this 150
acres lying in this picturesque valley forty miles from
St. Louis was a dairy farm.

Hauser, an industrial engineer with Cie Industrielle
des Ceramiques, Electroniques of Orsay, France, had
come to look over the world’s first commercial uranium
plant. But this pastoral scene seemed far from such
industrial distinction.

The winding blacktop road straightened out along the
bottom of the ridge. The Frenchman could see the old
and new in a glance—the new yellow and blue sign
“Mallinckrodt Nuclear Corporation” against the big dai
barn in the background. Back from the road was MCW's
Hematite plant, a fast-growing “infant” in a new industry.

Horton, administration and sales manager of the cor-
poration, turned the car off the county road into the
plant area, Hauser saw four modern buildings set down
in a pasturé. with thirty-three thousand square feet of
space in them, almost three times the 12,500 square feet
of the original plant, Horton tells him that, with equip-
ment, here was a two-million-dollar Mallinckrodt invest,
ment in the commercial nuclear power industry. Sémie__
sixty people are employed. here Eleven more at the
St. Louis office are eonmected with the operation.

MCW giitered the commercial uranium industry in
January 1956 with the formation of the Special Metals

)

DURING STARTUP. of the new pelleting plant, engineer Joe
Clumpner checks temperature sight tube on sintering furnace.


¢ To develop a groundwater and contaminant transport model for the Hematite Site that can be used to
predict long-term fate of contaminants, to guide future sampling programs, and to evaluate remedial
alternatives.

« To address data gaps identified during previous investigations.

A technical approach for achieving the goals and objectives of the RI was presented in a RI/FS Work
Plan (LBG 2003) submitted by WEC to the Missouri Department of Natural Resources (MDNR) in
May 2003. In response to the conditional approval of the RI/FS Work Plan (MDNR 2003), a series of
task-specific work plans (TSWPs) were prepared and submitted to MDNR. The TSWPs, which were
reviewed but not formally approved by MDNR, were aligned with the aforementioned RI objectives and
provided additional details regarding the following field activities:

¢ Sampling and analysis of Site and upstream (background) surface water and sediment for
radiological contaminants of potential concern (RCOPCs) and chemical contaminants of potential
concern (CCOPCs), including the installation of surface water gauging stations (SAIC 2004a).

« Sampling and analysis of surface soil for RCOPCs and CCOPCs (SAIC 2004b).

¢ Sampling and analysis of subsurface overburden soil, including the installation of temporary monitoring
wells that enabled sampling and analysis of overburden groundwater for volatile organic compound
(VOC) and radiological contamination detected during previous investigations (SAIC 2004c).

* — Drilling and installation of bedrock wells to supplement the pre-RI monitoring network, including
(1) discrete interval sampling and analysis of groundwater for VOCs in the new bedrock boreholes
and select domestic supply wells, and (2) slug testing at selected wells to measure hydraulic
conductivities of the overburden and bedrock formations (SAIC 2004d).

¢ Sampling and analysis of surface and near-surface soil for RCOPCs and CCOPCs in locations
remote from the Hematite Site (SAIC 2004e) to obtain characteristics of soil not likely to have been
impacted by previous operations (i.¢., local background).

¢ Baseline groundwater sampling and analysis for RCOPCs, CCOPCs, and basic water quality
parameters at pre-RI, newly installed bedrock and temporary overburden groundwater monitoring
wells at the Hematite Site, including groundwater level measurements at these wells (SAIC 2004f).

As a result of a detailed review of the RI/FS Work Plan, modifications were made to the original
technical approach. These modifications and the technical basis for making these changes were presented in
the TSWPs and were based on input from the RI Contractor (SAIC and its subcontractors), WEC, and MDNR.

1.2. SCOPE AND ORGANIZATION OF THE REPORT
This Report presents the results of RI field activities performed from April 2004 through
January 2005 in accordance with the aforementioned RI/FS Work Plan and TSWPs. It also provides a

summary of the results of the gamma survey conducted in April 2003 and sampling and analyses
conducted in December 2003 of soils underneath buildings at the Hematite Facility (SAIC 2003a).

A-44


FFCF Site January 2003
EI

CA for Response Action for of f-stte Groundwater

1.0 INTRODUCTION

On behalf of Westinghouse Electric Company, LLC. (Westinghouse), Cabrera Services, Inc.
(CaBRERA) has prepared this Engineering Evaluation and Cost Analysis (EE/CA) to evaluate
potential removal action alternatives to address the presence of volatile organic compounds
(VOCs) that have been detected in the local aquifer in the vicinity of the Westinghouse
Former Fuel Cycle Facility (FFCF).

2.0 SITE CHARACTERIZATION

Site characterization includes discussion of: the Site description and background information;
previous removal actions; the source, nature, and extent of contamination; summary of
analytical data; the Site conditions justifying a removal action; and a streamlined risk
evaluation.

21 Site Description and Background

This section is divided into two parts: a general discussion of the entire FFCF (the “Site”) and
a discussion specifically about off-site groundwater conditions.

211° Site

The Site is located in the eastern portion of Missouri in Jefferson County near the town of
Hematite. (Figure } Site Location Map.) It fronts the eastbound lane of Missouri State Road
P, between the hills to the northwest and the terrace and floodplain of Joachim Creek to the
southeast. The topography slopes gently to the southeast eventually blending with the alluvial
floodplain deposits of the Joachim Creek, which runs along the southeastern edge of the Site
property and eventually flows into the Mississippi River.

The area surrounding the Site is mainly suburban residential. Groundwater is widely used
within four miles of the Site as the primary source of household water for the community. At
least 11,771 people are served by public wells in the area, and an estimated 978 people are
served by private wells. The closest wells are located within 1/4 mile of the Site.

The facility was opened in the mid-1950’s by Mallinckrodt Chemical Works and through the
mid 1970's was owned and operated by a variety of entities, including United Nuclear
Corporation and Gulf Nuclear Fuels Company. Until the early 1970's, the site was heavily
involved in producing uranium for the United States Navy and United States Department of
Energy. In the Mid-1970’s Combustion Engineering Inc. acquired the property and began
commercial nuclear fuel production. Westinghouse purchased the facihty in April 2000
There are currently no manufacturing operations at the Site.

Primary functions at the Site throughout its history have included the manufacture of uranium
metal and uranium compounds from natural and enriched uranium for use as nuclear fuel
Specifically, operations included the conversion of uranium hexafluoride gas of various ?°U
enrichments to uranium oxide, uranium carbide, uranium dioxide pellets, and uranium metal.

CABRERA SERVICES, INC. Pace 3

-a\ 002369


Site January 2003
EE/CA tor Response Action for off-site Groundwater

These products were manufactured for use by the federal government and government
contractors and by commercial and research reactors approved by the Atomic Energy
Commission. Research and development was also conducted at the Site, as were uranium
scrap recovery processes.

21.2 Off-Site Groundwater Impacts

In December 2001, the Missour: Department of Health and Senior Services (DHSS)
conducted annual radiological monitoring (gross alpha/gross beta) of four private wells near
the Site. Samples were also collected for volatile organic analyses at the request of the
Department of Natural Resources. Results of that sampling revealed that one of the private
drinking water wells sampled by DHSS exhibited VOC concentrations, including
tetrachloroethylene (PCE), and trichloroethylene (TCE), above drinking water standards.
This well (ie., Well #3) is located northeast of the FFCF at a residence situated on
Westinghouse property and leased by Westinghouse. This well had been last sampted in 1996
for VOCs, and did not contain VOCs at that time. Once informed of this finding,
Westinghouse and the Missouri Department of Natural Resources (DNR) conducted follow-
up testing. In March 2002, Westinghouse tested an additional 20 wells, five of which were
found to be impacted by VOCs, (bringing the total number of affected wells to six). In April
2002. DNR and DHSS sampled additional private wells, while Westinghouse conducted
repeat sampling of those previously sampled. Analytical results of this sampling event in
April showed no additional private wells were affected. In July 2002, the first round of
quarterly sampling was conducted, and detectable levels of VOCs were found in two more
wells, bringing the total number of affected wells to eight. Except for the well #3, all of the
affected wells are at residences located in the affected area located southeast of the Site
Figure 2 shows the affected area.

The affected wells are all reportedly open to both the Jefferson City Formation and the
underlying Roubidoux Formation. Hydrogeologic evaluations of the Site area (Leggette,
Brashears & Graham, Inc., November 2002) have concluded that groundwater in the
Jefferson City Formation has been impacted by the VOCs of interest, whereas groundwater in
the deeper Roubidoux Formation generally has not.

Based on these findings, and in consultation with DNR, Westinghouse determined that a time-
critical removal action was appropriate to mitigate potential risks to residents in the vicinity of
the Site. Westinghouse prepared an Action Memorandum (Action Memorandum, Former
Fuel Cycle Facility, Off-site Groundwater, June 2002) to document its response. Components
of the Action Memorandum are discussed in Section 2.2.

2.2 Previous Removal Actions

Previous investigations are described in detail in the Action Memorandum, June 2002.
Actions taken subsequent to those investigations are presented below.

Major components of the Action Memorandum that Westinghouse has implemented include
the following:

CABRERA SERVICES, INC. PAGE 4

A-ar

002370


U7

Special Exposure Cohort Tg US. Sopatmon Mica and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
liness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 05/31/2007
Petitioner Authorization Form Page 1 of 2

instructions:

If you wish to petition HHS to consider adding a class of employees to the Special Exposure Cohort and you
are NOT either a member of that class, a survivor of a member of that class, or a labor organization
representing or having represented members of that class, then 42 CFR Part 83, Section 83.7(c) requires
that you obtain written authorization. You can obtain such authorization from either an employee who is a
member of the class or a survivor of such an employee. You may use this form to obtain such authorization
and submit the completed form to NIOSH with the related petition. Please print legibly.

For Further Information: If you have questions about these instructions, please call the following NIOSH
toll-free phone number and request to speak to someone in the Office of Compensation Analysis and
Support about an SEC petition: 1-800-356-4674.

Authorization for Individual or Entity to Petition HHS on Behalf of a Class of Employees for

Addition to the Special Exposure Cohort

Name of Class Member or Survivor

Street Adaress ot Class Member or Survivor Apt. # P.O. Box

City, State, Zip Code of Class Member or Survivor

do haraby anthnriza-

Name or reuuoner

Address of Petitioner. a -_ Ant # P.O. Box

City, State and Zip Code of Petitioner

to petition the Department of Health and Human Services on behalf of a class of employees
that inc!“---

Name ot - fe eg ee eee eee cece e-, 26'S Survivor)

for the addition of the class to the Special Exposure Cohort, under the Energy Employee’s
Occupational iliness Compensation Program Act (42 U.S.C. §§ 7384-7385).

In providing this authorization, | recognize that the petitioner named above will have all the rights
af a nafitinnear ae nroviderfar under 49 CFR Part 83.

L~- &-O7

Vyas UI Wiave ieiiWE! UL OULNIVUL Date

Name or Social Security Number of First Petitioner: “